Tax Insights: Gerbro Holdings – TCC did not apply offshore investment fund rules to investment in tax haven
In its decision in Gerbro Holdings Company v. The Queen, the Tax Court of Canada refused to apply the offshore investment fund tax rules (in section 94.1 of the Income Tax Act (Canada) to interests held by a Canadian investor in funds based in low- or no-tax jurisdictions—in this case five funds based in the Cayman Islands, the Netherlands Antilles and the British Virgin Islands.
Tax Insights: Mutual fund switch corporations – Draft legislative proposals implement 2016 federal budget measures
On July 29, 2016, the Department of Finance released for consultation draft legislative proposals implementing the 2016 federal budget measure that is intended to eliminate the tax-deferred switching of different classes of shares issued by a mutual fund corporation – commonly referred to as “switch funds.”
Tax Insights: Bill C-29 – Effect on asset management industry
Bill C-29, Budget Implementation Act, 2016, No. 2, which received first reading on October 25, 2016, includes measures that affect the asset management industry.
Tax Insights: Alert for asset managers – New final section 871(m) regulations on dividend equivalent payments may apply to you
On September 17, 2015, the IRS released final and temporary regulations under Section 871(m) of the Internal Revenue Code that prescribe rules for treating “dividend equivalent payments” with respect to US equities as US-source dividend income.
Forging a winning culture
The first question an analyst is likely to ask a CEO is: ‘What is your strategy for the future?’ A better question would be: ‘Do you have the right culture to succeed?’
CFOs: Opportunities and roles in the cloud - Five questions you should ask
Cloud computing can reduce IT and business costs, and it is fast becoming a powerful means for growth.
Re-energizing Finance: The Organization Challenge
Whatever the size of their teams, the onus is on CFOs today to leverage every part of the finance organization to deliver value beyond traditional transaction processing and control.
Practical guide to IFRS: IFRS 10 for asset managers
This publication sets out a framework for an asset manager to use when interpreting IFRS 10 to determine whether control exists − in particular, the assessment of principal versus agent.
The top 10 issues faced by senior finance executives
The following brochure discusses the top 10 issues keeping finance executive awake at night and who at PwC can help your organization improve your finance effectiveness.