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  • Article

    Canadian Entrepreneurs' Incentive: How Incentivized Will Canadian Entrepreneurs Be?

    Tax proposals contained in the 2024 Federal Budget (the "2024 Budget") propose to increase the capital gains inclusion rate from one-half to two-thirds...
    CanadaTax
    Miller Thomson
    Miller Thomson
  • Article

    Canadian Foreign Reporting Obligations

    With the recent release of the ICIJs' investigation of offshore tax havens used by a law firm based in Panama, the question of what Canada is doing to ensure that its taxpayers are disclosing offshore assets and reporting the related income is front and centre in the minds of many taxpayers.
    CanadaTax
    Collins Barrow National Incorporated
    Collins Barrow National Incorporated
Article

Characterizing The Assumption Of Obligations When Determining The Proceeds Of Disposition

In Daishowa-Marubeni International Ltd. v. Canada, 2013 SCC 29, the Supreme Court of Canada held 9:0 that Daishowa-Marubeni International’s proceeds from the disposition of two forest tenures should not include the reforestation obligations that were assumed by the purchasers.
CanadaTax
Gowling WLG
Gowling WLG
  • Article

    Corporate Reorganization Not GAARable

    On June 3rd, 2009, the Tax Court found in favour of the taxpayer in "Collins & Aikman Products Co. et al v. The Queen".
    CanadaTax
    Borden Ladner Gervais LLP
    Borden Ladner Gervais LLP
  • Article

    CRA's New Position On US LLLPs And LLPs

    On May 26, 2016, the Canada Revenue Agency announced that it will consider Florida and Delaware limited liability limited partnerships and US limited liability partnerships to be corporations for Canadian tax purposes.
    CanadaTax
    Grant Thornton
    Grant Thornton
  • Article

    Crowdfunding: The Tax Implications Of A Popular Fundraising Vehicle

    Crowdfunding is defined by Wikipedia as "the practice of funding a project or venture by raising many small amounts of money from a large number of people, typically via the Internet."
    CanadaTax
    Collins Barrow National Incorporated
    Collins Barrow National Incorporated
  • Article

    Department Of Finance Canada Issues Press Release Regarding The July 18, 2017 Tax Proposals

    The consultation period for the July 18, 2017 tax proposals ended on October 2, 2017. In the course of the consultations, over 21,000 written submissions were received by the Government.
    CanadaTax
    Torkin Manes LLP
    Torkin Manes LLP
  • Video

    From A Tax-Saving Perspective: What Should I Look For When Buying Business Assets Or Shares? -- Ali Spinner Answers (Video Content)

    Question: What are some tax considerations in deciding whether I should buy the assets of a business or the shares of a business?
    CanadaTax
    Crowe Soberman LLP
    Crowe Soberman LLP
  • Article

    IRS Proposes Broad Limit On Intercompany Debt

    The Internal Revenue Service has proposed new regulations that would generally treat intercompany indebtedness in corporate groups with 80% common ownership as equity for U.S. tax purposes.
    CanadaTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    Morguard Corp. v. R.

    In the recent decision Morguard Corp. v R., 2012 TCC 55, the Tax Court of Canada considered the proper tax treatment of a break fee in the hands of a recipient as a result of a failed takeover bid.
    CanadaTax
    McMillan LLP
    McMillan LLP
  • Article

    MT Federal Budget Review - March 22, 2016: Introduction

    On March 22, 2016, Minister of Finance Bill Morneau tabled the highly anticipated 2016 Federal Budget (the "Budget"), the Liberal Government's first budget, entitled "Growing the Middle Class".
    CanadaTax
    Miller Thomson
    Miller Thomson
  • Article

    New Business Tool Kit Chapter 4 – Payroll Taxes

    Irrespective of the form of business in which you operate, if you are going to have employees then you will have to contend with payroll taxes. The brief summary that follows will give you some guidance in the rules and regulations of the various taxing authorities.
    CanadaTax
    Crowe
    Crowe
  • Article

    New Reporting Requirements For Internet-Based Businesses

    A corporation, partnership or self-employed individual earning income from one or more Internet webpages or websites must comply with reporting requirements.
    CanadaTax
    Gowling WLG
    Gowling WLG
  • Article

    Nova Scotia Announces Increases To The Nova Scotia Film Industry Tax Credit

    On March 8, 2005, Nova Scotia Premier John Hamm announced that the Nova Scotia Government has extended the province’s film tax credit for an additional ten years. The Government also announced that it is increasing the tax credit as follows:
    CanadaTax
    Goodmans LLP
    Goodmans LLP
  • Article

    Paul Kvas v. The Queen, 2016 DTC 1169

    The appellants appealed from the section 160 assessment and their appeals were heard on common evidence.
    CanadaTax
    Borden Ladner Gervais LLP
    Borden Ladner Gervais LLP
  • Article

    Proposed Simplification to U.S. Rules Regarding Tax-Free International Reorganizations

    A change in how tax-free "statutory" mergers can take place.
    CanadaTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    Quebec Company Law Reform – Changes Of Interest To Tax Planners

    On October 7, 2009, the Quebec Finance Minister tabled Bill 63, entitled Business Corporations Act (the Bill), in the Quebec National Assembly.
    CanadaTax
    Blake, Cassels & Graydon LLP
    Blake, Cassels & Graydon LLP
  • Article

    Reducing Red Tape: Restoring The Alberta Advantage

    The Government of Alberta has taken significant steps to promote and facilitate investment in the province by removing residency requirements for corporate directors and reducing the corporate tax...
    CanadaTax
    Cassels
    Cassels
  • Article

    Release Of The 2021 Canadian Budget

    On April 19, 2021, Canada's Deputy Prime Minister and Minister of Finance, Chrystia Freeland, released the first official budget in the past two years, titled, Federal Budget 2021...
    CanadaTax
    Dickinson Wright PLLC
    Dickinson Wright PLLC
  • Article

    Restrictive Covenants In M&A Deals: A Timely Refresher On Tax Rules

    There are many issues to address in a merger and acquisition transaction. In most purchase and sale transactions the purchaser, after paying the seller consideration to acquire the business...
    CanadaTax
    Miller Thomson
    Miller Thomson
  • Showing 261–280 of 1608 results

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