As U.S. lawmakers move forward with a sweeping tax reform bill, new provisions targeting "unfair" foreign tax regimes are raising alarm bells for international investors. Section 899 of the proposed legislation seeks to override existing treaty protections, with potential consequences for Canadian businesses, investment funds and cross-border financial planning.

Speaking recently with Investment Executive, Laura Gheorghiu, a partner in Gowling WLG's national Tax Group in Montreal, commented on the potential treaty impacts of the proposed changes and the broader implications for Canada and other countries.

"We're not in this alone — I think that's an important thing to keep in mind," Gheorghiu said. "These rules apply to a very large number of countries," requiring a concerted response to address U.S. concerns.

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