American Tax Considerations in the Drafting of Canadian Joint Operating Agreements
DOI:
https://doi.org/10.29173/alr540Keywords:
Energy Law, Petroleum LawAbstract
Many operators in Canada's oil and gas industry are subject to taxation under the United States Internal Revenue Code. In their Canadian activities, operations and agreements, these operators seek to preserve any tax benefits that they may have under the income tax laws of the United States. This article outlines the tax advantages which the United States operator wishes to preserve, such as avoidance of the status of an on Canadian operators not subject to United States tax laws, and suggests draft clauses that may be included in Canadian joint operating agreements to preserve United States tax benefits for the American operator.Downloads
Issue
Section
License
For Editions following and including Volume 61 No. 1, the following applies.
This work is licensed under a Creative Commons Attribution-Noncommercial-No Derivative Works 4.0 License
For Editions prior to Volume 61 No. 1, the following applies.
Author(s) retain original copyright in the substantive content of the titled work, subject to the following rights that are granted indefinitely:
- Author(s) grant the Alberta Law Review permission to produce, publish, disseminate, and distribute the titled work in electronic format to online database services, including, but not limited to: LexisNexis, QuickLaw, HeinOnline, and EBSCO;
- Author(s) grant the Alberta Law Review permission to post the titled work on the Alberta Law Review website and/or related websites.
- Author(s) agree that the titled work may be used for educational or instructional purposes and/or in educational or instructional materials. The author(s) acknowledge that the titled work is subject to other such "fair dealing" provisions and applicable legislation.
- Author(s) grant a limited license to those accessing the titled work from an electronic database or an Alberta Law Review website to download the titled work onto their computer and to print a copy for their own personal, non-commercial use, subject to proper attribution.
To use the journal's content elsewhere, permission must be obtained from the author(s) and the Alberta Law Review.