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Dentons lawyers named in Who’s Who Legal Thought Leaders: Global Elite 2019 guide
Dentons is proud to congratulate six of our lawyers who have been recognised by Who’s Who Legal in its Thought Leaders: Global Elite 2019 guide.
With all the changes and announcements in 2018, our Eurozone Hub has collated the following supervisory outlook for 2019 as a non-exhaustive “Playbook” for Banking Union Supervised Institutions and other regulated market participants already based in or otherwise relocating to the EU and/or the Eurozone.
Canada Federal Budget 2019
In the wake of the release of the much-anticipated 2019 Federal Budget, members of Dentons’ Tax group, together with a team at Wolters Kluwer, have prepared a Special Report which provides a detailed analysis and concise summary of the changes featured in the Budget.
Global tax guide to doing business in... 2019
Our Global tax guide to doing business in… highlights the complexities of corporate tax systems in 28 countries across Africa, the Americas, Asia Pacific, Australia and Europe.
US Policy Scan 2019
In Policy Scan 2019, Dentons' US Public Policy team's annual analysis of the legislative and political landscape, we take a close look at the issues, questions and conflicts that will dominate the dialogue on Capitol Hill and in the White House over the coming year.
Starting your career as a student at Dentons exposes you to a world of experience and opportunities
With 175 locations in 78 countries, Dentons is home to top-tier talent that is found at the intersection of geography, industry knowledge and substantive legal experience. Working with Dentons, you will have the opportunity to learn from the best lawyers in the industry at the largest law firm in the world.
The Legal 500 EMEA 2019 recognizes over 130 Dentons lawyers
The 2019 edition of The Legal 500 Europe, Middle East and Africa has recognized 133 Dentons lawyers, of which 89 have been included in the elite “Leading Lawyers” list, while 44 are listed as “Next Generation Lawyers”.
Dentons launches Market Insights publication: “Digital Transformation and the Digital Consumer”
Dentons, the world’s largest law firm, has launched a new Market Insights publication entitled “Digital Transformation and the Digital Consumer”, which examines the legal implications of the online economy.
Dentons ranks across 68 tables securing 109 individual and 43 practice rankings in Chambers USA
Global law firm Dentons earned 109 individual and 43 practice rankings - a 20% increase over last year - in the most recent edition of Chamber USA.
On December 13, 2017, the Department of Finance introduced revised rules relating to distributions of income (referred to as “income sprinkling”) from a private corporation. Those rules lend some clarity to previous proposals that were vague in nature.
On July 18, 2017, the Department of Finance introduced a consultation paper which included far-reaching proposals seeking to limit the ability to use legal “income sprinkling” plans. Those proposals imposed a vague reasonableness test that was anticipated to be a minefield of tax litigation. That reasonableness test applied to any “split income” (which included, generally speaking, income from the business of a related individual and a corporation to which a related individual was connected). It was proposed that the labour and capital contributions, and risks assumed by the recipients of that income would be considered. To the extent that the income was not considered reasonable, it would be taxed at the highest marginal tax rate.
Submissions to the Department of Finance by the tax community highlighted concerns and unpredictability arising from the reasonability test. As a consequence, the Department of Finance committed to a revision of the proposals. Dentons wrote on both the proposals and revision process.
The December 13, 2017 release proposed to simplify and limit the changes effective January 1, 2018. The rules will still apply to income received by individuals from a business to which they are related. However, several exclusionary “bright line” tests will remove individuals from the application of the rules. Among those are the following:
To the extent that distributions from a private corporation do not fall within one of the new bright line exceptions, they will still be subject to a reasonableness test.
Despite the proposed simplification, many established tax plans risk triggering the TOSI rules.
We urge owners of private corporations to consult with a Dentons tax advisor prior to structuring any distributions.
Please contact Mark Woltersdorf, Joel Nitikman, Marc-André Belanger, Marie-Claire Dy, Jehad Haymour, Emmanuel Sala, Tony Schweitzter, or another Dentons’ tax advisor if you have any questions