Concept
ATO Disclosure
Chopp v. R., 98 DTC 6014, [1998] 1 CTC 407 (FCA) / Nuvei v. Arrap - NSW Supreme Court finds that a post-closing voluntary disclosure by the target so as to deplete escrowed funds did not violate a duty to cooperate with the vendor
"After the closing, the Company sought, without significant success, to receive certifications from the members of the LLCs and LLPs as to their residency status. Towards the end of the 18-month period, the Company made a voluntary disclosure to the ATO. The ATO determined that, since there was inadequate evidence of the residency status of the beneficial recipients of the deemed dividend, withholding tax at the 30% rate was payable, which was then paid."
Related Ideas
- ATO DeterminationDeyab v. Canada, 2020 FCA 222 · Nuvei v. Arrap - NSW Supreme Court finds that a post-closing voluntary disclosure by the target so as to deplete escrowed funds did not violate a duty to cooperate with the vendor
- Implied ObligationDeyab v. Canada, 2020 FCA 222 · Nuvei v. Arrap - NSW Supreme Court finds that a post-closing voluntary disclosure by the target so as to deplete escrowed funds did not violate a duty to cooperate with the vendor
- Escrow FundsDeyab v. Canada, 2020 FCA 222 · Nuvei v. Arrap - NSW Supreme Court finds that a post-closing voluntary disclosure by the target so as to deplete escrowed funds did not violate a duty to cooperate with the vendor