Canadian firms with minority U.S. shareholders may now be considered U.S. CFCs.
As a result of a recent change to the U.S. constructive ownership rules, which was enacted as part of U.S. tax reform in December 2017, Canadian entities with companies that have minority U.S. shareholders should consider whether there are any "new" U.S. controlled foreign corporations (CFCs) in the group.
Download this edition of Global Tax Adviser to learn more.
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