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The Joy of Canadian Tax: Show Me the Money!
A U.S. franchisor looking to expand into Canada has a daunting, but entrepreneurially acceptable, challenge ahead. One of the issues to be dealt with early on is: How will I be taxed at home and “abroad”? That's right: “abroad.” As tempting as it may be to view Canada as the 51st state, it just isn't so. North of the 49th parallel of latitude lies a foreign country complete with all the usual structural pitfalls.
Canada's tax system has many of the outward appearances of the U.S. system. There are some serious structural differences (such as the magnitude of absolute rates, marginal rates, federal-provincial arrangements, etc.), but the basic fact is that each country imposes taxes on income derived from commercial activity taking place within its borders, and has special rules to be applied when certain types of payments cross that 49th parallel. Fortunately, there is a tax treaty between the U.S. and Canada to bring better order, fairness, and balance to the process.
The DOJ's Corporate Enforcement Policy: One Year Later
The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.
Use of Deferred Prosecution Agreements In White Collar Investigations
This article discusses the practical and policy reasons for the use of DPAs and NPAs in white-collar criminal investigations, and considers the NDAA's new reporting provision and its relationship with other efforts to enhance transparency in DOJ decision-making.
The DOJ's New Parameters for Evaluating Corporate Compliance Programs
The parameters set forth in the DOJ's memorandum have implications not only for the government's evaluation of compliance programs in the context of criminal charging decisions, but also for how defense counsel structure their conference-room advocacy seeking declinations or lesser sanctions in both criminal and civil investigations.
How AI Has Affected PR
When we consider how the use of AI affects legal PR and communications, we have to look at it as an industrywide global phenomenon. A recent online conference provided an overview of the latest AI trends in public relations, and specifically, the impact of AI on communications. Here are some of the key points and takeaways from several of the speakers, who provided current best practices, tips, concerns and case studies.