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North America

US and Canadian founders and groups building a European platform, and the exit charges they meet on the way out.

20 PUBLICATIONS
North America
Selling Canadian Real Property From a European Holding
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North America
Canadian Thin Capitalisation and Intragroup Debt
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North America
Part XIII Withholding on Payments to a Dutch Company
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North America
A Canadian ULC and the Treaty Denial Problem
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North America
State Nexus: The Tax Nobody Budgets For
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North America
US Estate Tax on European Holdings With US Assets
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North America
Remote US Employees and a European Permanent Establishment
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North America
Selling a US Subsidiary Out of a Dutch Holding
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North America
Delaware or Amsterdam: Where the Holding Should Sit
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North America
Form 5471 and What a Dutch Subsidiary Triggers
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North America
A US Citizen on the Board of a Dutch BV
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North America
The Limitation on Benefits Article in the US Netherlands Treaty
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North America
Effectively Connected Income and the Dutch Company
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North America
FIRPTA: Selling US Real Estate From a European Structure
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North America
A US Shareholder of a Dutch BV and the GILTI Charge
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North America
Check the Box and What It Does to a Dutch Structure
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North America
A US LLC Under a Dutch Holding: The Hybrid Mismatch
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Exit Tax
Canada’s Departure Tax: The Disposal You Did Not Make
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Exit Tax
The US Expatriation Tax: What It Costs an American Founder to Stop Being One
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