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  • Article

    Introduction - MT Federal Budget Review

    Minister of Finance Jim Flaherty today tabled the 2014 Federal Budget entitled The Road to Balance: Creating Jobs and Opportunities.
    CanadaTax
    Miller Thomson
    Miller Thomson
  • Article

    Is This The End Of Professional Corporations? Three Things Everyone Needs To Know About The Latest Comments From Finance Minister Morneau

    Following Finance Minister Bill Morneau's magical misdirection on Monday, October 16, 2017 (whereby the federal Liberal government made us look one way in their announcement ...
    CanadaTax
    Wildeboer Dellelce LLP
    Wildeboer Dellelce LLP
Article

Loan Restructuring Triggers GAAR

On April 29, 2009, the Tax Court of Canada held in “Lehigh Cement Limited v. The Queen” that the general anti-avoidance rule (“GAAR”) applied to a series of transactions which resulted in interest payments by Lehigh on debt held by a related non-resident corporation being restructured as interest payments to an arm’s length non-resident bank in order to access the former “5/25” domestic withholding tax exemption for interest on certain arm’s length corporate debt.
CanadaTax
Borden Ladner Gervais LLP
Borden Ladner Gervais LLP
  • Article

    Municipalities And First Nations - Importance Of "Qualified Donee" Registration

    The Income Tax Act, Canada (the "Act") provides that only "qualified donees" can issue official tax receipts for gifts from individuals and corporations.
    CanadaTax
    Norton Rose Fulbright Canada LLP
    Norton Rose Fulbright Canada LLP
  • Article

    Personal vs Corporate Donations - The Alberta Perspective

    In December 2014, my colleague Regan Exner wrote a blog titled ‘Should I Make Charitable Donations Personally or Through My Company?’
    CanadaTax
    MNP LLP
    MNP LLP
  • Article

    Potentially Adverse Tax Results For Incorporated Employees

    On October 31, 2011, the Department of Finance proposed changes to the Income Tax Act that effectively put an end to the potentially advantageous tax planning strategy of having an employee agree to provide their services to their employer through a corporate entity (a "Personal Services Business").
    CanadaTax
    DLA Piper
    DLA Piper
  • Article

    Recent Pronouncements on Interest Deductibility and Funds Borrowed to Acquire Common Shares

    CanadaTax
    Goodmans LLP
    Goodmans LLP
  • Article

    Supreme Court Of Canada To Hear Tax Rectification Case

    On November 19, 2015, the Supreme Court of Canada granted leave to appeal in Canada (A.G.) v. Groupe Jean Coutu (PJC) inc., 2015 QCCA 838, which addresses the question of when rectification will be granted in the tax context.
    CanadaTax
    Bennett Jones LLP
    Bennett Jones LLP
  • Article

    Tax Planning Opportunity Closed: Proposed Amendments To The Income Tax Act (Canada) Will Tax Non-Competition Payments

    CanadaTax
    Torys
    Torys
  • Article

    The Future Of Intelligent Diagramming With Raymond Adlington, Tax Partner | Miller Thomson

    As electronic tools became available, we started using Corel Draw initially, because law firms in the 90s were addicted to Word Perfect.
    CanadaTax
    Blue J Legal
    Blue J Legal
  • Article

    BEPS Tail Shouldn’t Wag Global Investment Dog

    I spoke recently on a panel in Tokyo on the future of international tax planning after BEPS (the OECD’s & G20’s Action Plan to counter Base Erosion & Profit Shifting).
    GlobalTax
    Bennett Jones LLP
    Bennett Jones LLP
  • Article

    The Cross-Border Quarterly Report - September 2018

    The Cross-Border Quarterly Report is a snapshot of transactional activity across the Canada-U.S. border.
    CanadaLitigation, Mediation & Arbitration
    Osler, Hoskin & Harcourt LLP
    Osler, Hoskin & Harcourt LLP
  • Article

    Producing In Canada

    Canada's film, television, and interactive digital media production industry continues to thrive as a multibillion-dollar sector, supported by world-class facilities, skilled workforce, and competitive advantages including lower production costs and favorable exchange rates. Dentons' comprehensive guide examines the federal and provincial tax credits, funding programs, and incentives available to producers choosing Canada as their production destination. The guide details eligibility requirements and key fi
    CanadaMedia, Telecoms, IT, Entertainment
    Dentons Canada LLP
    Dentons Canada LLP
  • Article

    A Note On The Impact Of The Trump Presidency On Cross-Border Businesses

    On Tuesday, the U.S. electorate sent a strong signal to the U.S. political and economic establishment, as well as the rest of the world.
    CanadaTax
    Osler, Hoskin & Harcourt LLP
    Osler, Hoskin & Harcourt LLP
  • Article

    Advance Income Tax Ruling Requests For “major Investments” In Canada To Take Priority

    The Canada Revenue Agency has announced a new policy to prioritize advance income tax ruling requests for investments of $1 billion or more in Canada. This initiative aims to provide greater tax certainty and reduce risks for major investors, potentially accelerating large-scale project development and strengthening Canada's economic competitiveness. However, questions remain about implementation timelines and potential impacts on smaller ruling requests.
    CanadaTax
    Gowling WLG
    Gowling WLG
  • Article

    Canadian Government Pushes Ahead With Proposed Tax Rules In Spite Of Pitfalls

    On October 15, 2012, the Canadian Minister of Finance tabled in the House of Commons a Notice of Ways and Means Motion to implement proposed tax changes.
    CanadaTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    Canadian Tax Facts 2025

    Every year, people need to update themselves on the tax facts of the country where they live or own a business.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Controversial Budget Proposal Subject To Change

    The last edition of CanadianTax @ Gowlings contained a discussion of a significant proposal from the 2007 Canadian Federal Budget which would significantly curtail the deductibility of interest on money borrowed by Canadian corporations to finance foreign affiliates.
    CanadaTax
    Gowling WLG
    Gowling WLG
  • Article

    Foreign-Controlled Canadian Corporations Beware

    On August 14, 2012, the Department of Finance released draft legislation that includes a revised version of the foreign affiliate dumping proposals tabled with the March 29 Federal Budget.
    CanadaTax
    Bennett Jones LLP
    Bennett Jones LLP
  • Article

    Government Of Canada Reverses Course: Deferral Of The Increase To Capital Gains Inclusion Rate To January 1, 2026

    In a welcome development for taxpayers, the Department of Finance ("Finance") announced on January 31, 2025 (the "Announcement") that it would defer the implementation of the proposed...
    CanadaTax
    Miller Thomson
    Miller Thomson
  • Showing 121–140 of 1608 results

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