"Tower Financing: Deduction Denied", January 2012

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"Tower Financing: Deduction Denied", January 2012

Author(s): Peters, Matthew

Date: January 13 2012

Taxpayers that have implemented cross-border tower financing structures and that have claimed a Canadian tax deduction for any U.S. taxes paid should revisit their structures carefully in light of the Tax Court of Canada’s recent decision in FLSMIDTH Ltd., v. The Queen (2012 TCC 3), which is the Court’s first decision concerning tower structures.

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