Josh Morry

New York, New York, United States Contact Info
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Experience & Education

  • Akin Gump Strauss Hauer & Feld LLP

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Publications

  • Interest Deductibility and Interest Inclusion

    Canadian Tax Foundation

    The tax treatment of interest plays a crucial role in decisions relating to the capitalization of a business and the appropriate matching of deductible expenses to taxable revenues. As a result, this paper focuses on a selection of the tips, traps, and nuances related to the deductibility and inclusion of interest under the Income Tax Act (Canada). The topics canvassed in this paper represent an assortment of difficult and interesting issues associated with interest deductibility and inclusion.…

    The tax treatment of interest plays a crucial role in decisions relating to the capitalization of a business and the appropriate matching of deductible expenses to taxable revenues. As a result, this paper focuses on a selection of the tips, traps, and nuances related to the deductibility and inclusion of interest under the Income Tax Act (Canada). The topics canvassed in this paper represent an assortment of difficult and interesting issues associated with interest deductibility and inclusion. This paper is intended to provide a general overview to young practitioners.

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  • Inbound Investment

    Canadian Tax Foundation

    Foreign investment into Canada is an issue that has attracted much attention in recent years. Along with economic policies and conditions, our domestic tax policy may have a significant impact on such investment. In this paper, the authors provide an update on current tax matters that affect foreign investment in Canada, including the current Canadian view of taxation and the tendencies of the tax authority regarding treaty shopping, the multilateral instrument, the use of a principal purpose…

    Foreign investment into Canada is an issue that has attracted much attention in recent years. Along with economic policies and conditions, our domestic tax policy may have a significant impact on such investment. In this paper, the authors provide an update on current tax matters that affect foreign investment in Canada, including the current Canadian view of taxation and the tendencies of the tax authority regarding treaty shopping, the multilateral instrument, the use of a principal purpose test (PPT) in Canada's treaties, interpretational issues with the PPT, recent views and experiences of technical matters related to the back-to-back loan rules for withholding tax and thin capitalization, and the foreign affiliate dumping rules.

Honors & Awards

  • Outstanding Young Alumni Award

    The University of Manitoba

  • Distinction in Corporate Finance Law

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    Completed Corporate Finance Law with a Distinction overall

  • Distinction in Intellectual Property Law

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    Completed Intellectual Property Law with a Distinction overall

  • Distinction in Principles of Financial Regulation

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    Completed Principles of Financial Regulation with a Distinction overall.

  • Distinction in the BCL Program at the University of Oxford

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    Completed the BCL Program with distinction overall

  • Cecil Black Memorial Prize

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    Highest Academic Standing in Taxation of Trusts and Estates

  • DA Thompson QC Prize in Law

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    Highest Academic Standing in Corporation Taxation

  • Dubienski Memorial Scholarship

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    For Postgraduate Studies in Law

  • Garth Erickson Memorial Prize

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    Highest Academic Standing in Commercial Law

  • Margaret Hypatia Crawford Prize

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    Highest Academic Standing in Third Year Law

  • Paul Norman Warren Memorial Prize

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    Highest Academic Standing in Securities Law

  • University of Manitoba Gold Medal in Law

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    Highest Academic Standing in the Combined Three Years of Law School

  • DA Thompson QC Prize in Law

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    Highest Academic Standing in Income Tax Law and Policy

  • Isbister Scholarship

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    Highest Academic Standing in Second Year Law

  • Dr. AW Hogg Undergraduate Scholarship

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    Highest Academic Standing in First Year Law

  • Lieutenant MM Soronow Scholarship

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    Highest Academic Standing in First Year Law

  • Neil James MacDonald Memorial Prize

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    Highest Academic Standing in Criminal Law and Procedure

  • Beta Gamma Sigma Honours Society

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    Academic Standing in the top 10% of Asper Students

  • Pitblado Scholarship

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    Robson Hall Dean's Honour List

    2014-2016

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