Legal Insights & Client Bulletins

Authoritative analysis on cross-border tax developments, bilateral regulatory shifts, and complex corporate jurisprudence authored by Michael Wheeler and the Altitude Law practice group.

Navigating IRS and CRA Bilateral Audits in Post-Reorganization Structures

An analytical examination of recent enforcement trends under the Canada–United States Income Tax Convention, focusing on transfer pricing adjustments, permanent establishment thresholds, and withholding tax exposure for multinational holding entities.

By Michael Wheeler, LL.B., LL.M.

Fiduciary Liability in Cross-Border Mergers: Protecting Executive Officers

Evaluating director and officer fiduciary duties during contested cross-border acquisitions, minority shareholder rights under provincial and state statutes, and the deployment of indemnification protocols.

By Arthur Pendelton, Senior Counsel

Enforcement of Foreign Arbitral Awards Across North American Jurisdictions

A comprehensive review of procedural hurdles and public policy defenses encountered when registering and enforcing international commercial arbitration awards in US and Canadian courts.

By Marcus Sterling, Trial Counsel