Tag Archives: subsidiary

Proposed regulations eliminate major US tax impediments to utilizing foreign subsidiaries for credit support

By: Tom Geraghty, Michael Greenberg and Zachary Nolan On October 31, 2018, the US Treasury and the IRS released proposed regulations under Section 956 (the Proposed Regulations), which substantially limit the application of Section 956’s “deemed dividend” rules to US corporations.1 This limitation on the application of Section 956 potentially increases the ability for US corporate borrowers … Continue Reading

What Israeli businesses should know before settling in Canada

Ted Maduri provides a brief overview of the main considerations that come with expanding your business into Canada, including: Business formation: which vehicle should you choose? Advantages of a branch office Advantages of a subsidiary corporation Where should you incorporate? How to set up the new company? What else should you keep in mind? Click here … Continue Reading
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