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Yesterday afternoon, the Canadian government tabled the 2015 Canadian Federal Budget.

On January 27, 2015, Yahoo Inc. announced its intention to seek an IRS private ruling that would confirm its view that the inclusion of a relatively small active business along with its stake in Alibaba Group Holding Ltd. would meet the "active business requirement" for a tax-deferred spinoff under the Internal Revenue Code.

Elected in October 2015, Canada's new Liberal government has proposed a tax platform featuring significant changes, including a four per cent increase (to 33 per cent) in the federal tax rate for individuals on income over C$200,000 and a 1.5 per cent drop in the middle-income tax rate.

In McKesson, the Tax Court upheld the CRA's transfer price adjustments (made pursuant to section 247 of the Income Tax Act (Canada).

We are pleased to provide our summary of tax measures contained in the Budget.

The OECD has recently released its Action Plan on Base Erosion and Profit Shifting.

The Ontario government presented its 2012 Budget (the "Budget") in the Ontario Legislature earlier this week.

A tax fishing expedition is where CRA goes to a third party to obtain general third party information that may aid them in auditing taxpayers rather than the subject of the information order.

In Canada, there is a taxation principal of integration which means that, as much as possible, the ultimate tax rate paid on a stream of income is the same regardless of whether it is earned...

A review of assessment appeals, rebate applications and tax changes.

The CRA's unfair policies concerning re-appropriating statute-barred credits were dealt another blow by the Federal Court ("FC") in Pomeroy's Masonry Limited (2017 FC 952).

Canada’s Scientific Research and Experimental Development (SR&ED) Program continues to be one of the most generous programs of its kind in the world.

The Canadian Scientific Research and Experimental Development Tax Incentive Program(SR&ED) encourages research and development by offering support to businesses that conduct scientific research...

Some taxpayers utilize corporate groups, which have been structured to multiply their access to the small business deduction (SBD).

The Fifth Protocol (the “Protocol”) to the Canada-US Income Tax Convention (the “Treaty”) introduces significant changes to the rules relating to corporate continuance and residence.

The Federal Government's 2018 Budget touts Canada's strong economic growth over the past two years, including real GDP growth of 3.2 per cent since the second quarter of 2016, an unemployment rate of 5.9 per cent...

In Achim Bekesinski and Her Majesty the Queen, the taxpayer, as director of a corporation, was personally reassessed by the Minister of National Revenue.