Joint Committee releases its submissions on synthetic equity arrangements and Reg. 102 withholding

Two Joint Committee submissions on 2015 Budget proposals have been released.

• The synthetic equity arrangement rules may capture dividends (e.g., safe income dividends) paid to a vendor during the period between the date of agreeing to sell shares and the closing
• Issues respecting the proposed relief from source deductions for non-resident employees working for non-resident employers relate inter alia to gaps between the Reg. 400 definition of a permanent establishment (used in the proposals) and the different Treaty definitions (e.g., the services PE in the Canada-US Treaty), how to apply a rule that presence in Canada must be less than 90 days in any 12 month period, vagueness respecting employer "certification" and application of the rule to LLCs.

Neal Armstrong. 26 May 2015 submissions under Joint Committee Submissions.