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Those of us following the Government of Canada's proposed tax changes since mid-July, experienced quite the wild ride last week.

The 2024 Fall Economic Statement (The Statement) was delivered by Government House Leader Karina Gould on December 16, 2024, following Finance Minister Chrystia Freeland's resignation...

A list of the "likelihood of success" opinions (frequently with percentage thresholds) with respect to a proposed transaction.

When determining whether a distribution of property should be made, the tax consequences not only for the taxpayer, but also for its legal representatives, must be considered.

The recent announcement by Ministers Shea and Kenney yesterday in a press release is much welcomed by Albertans as the Province has been hit by the worst flooding in its recent history.

Until October 31, 2006, income trusts were, by far, the fastest growing segment of Canadian listed securities. On that date, the federal government announced that the ability of existing listed income trusts to deduct distributions made to their unitholders in computing their taxable income would end on December 31, 2010.

A Panama-based trust with a Quebec contributor faced federal surtax and denied provincial abatement despite paying Quebec tax, creating a situation where it was taxed as residing nowhere in Canada. The Tax Court dismissed the appeal, calling the outcome unfair but mechanically required by statute, illustrating how some tax disputes are predetermined by clear statutory language regardless of perceived unfairness.

Widespread use of the depository system in Canada and the U.S. imposes practical limits on income trusts’ ability to monitor and control non-resident ownership of their units. Many income trusts are subject to restrictions on the ownership of their units by non-residents of Canada .

In the wake of the release of the much-anticipated 2015 Federal Budget, the Tax Group at Dentons has prepared a Special Report which provides a detailed analysis and concise summary of the changes featured in the Budget.

This article provides an introduction to the Foreign Account Tax Compliance Act for Canadians and analyzes Canada’s implementing legislation regarding FATCA.

The federal budget delivered in March 2012 contained two tax initiatives that are of particular concern to foreign companies with Canadian subsidiaries.

The decision of the Supreme Court of Canada in Daishowa-Marubeni International Ltd. v. Canada, 2013 SCC 29, was released on May 23, 2013, reversing the decision of the Federal Court of Appeal.

The American Jobs Creation Act of 2004 (AJCA) contains numerous international tax provisions that may be relevant to companies with foreign subsidiaries. Section 422 enables a U.S. corporation to repatriate eligible earnings from offshore affiliates during a designated taxable year with a modest U.S. tax cost. If specified investment requirements and other criteria are met, the taxpayer may claim an 85% dividends received deduction, but no foreign tax credit or deduction for foreign taxes paid.

On a day where the only thing Canadians could talk about was the resignation of the then finance minister on the date of the delivery of the government's 2024...

At the Canadian Tax Foundation's 68th Annual Tax Conference held in Calgary, the CRA orally announced further efforts to ensure fair treatment for Canadians impacted by the May 26, 2016, announcement...

At the International Fiscal Association conference held in Montréal on May 26, 2016, the CRA orally announced its conclusion that US LLLPs and US LLPs would be classified as corporations for Canadian tax purposes.

Registered charities in Québec often rely on volunteer directors, but can these directors be compensated while maintaining compliance with corporate and tax law? This analysis examines the legal framework governing...