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The Canada Revenue Agency has announced a new priority system for advance income tax ruling requests, targeting investments of at least $1 billion in Canada. This initiative aims to accelerate the tax certainty process for major investors by reducing processing times and providing binding guidance on how specific Income Tax Act provisions apply to proposed transactions.

On December 18, 2009, the Canadian Department of Finance (Finance) released a package of proposed foreign affiliate amendments (the 2009 Proposals).

On August 16, 2013, the Department of Finance released proposed amendments to the "foreign affiliate dumping" rules that were enacted in late 2012.

The Government indicated that it will be making further announcements in the coming days.

In Presidential MSH Corporation v. Marr Foster & Co. LLP, the Ontario Court of Appeal found that the Corporation's claim against its accountants, who had filed corporate tax returns after their due...

The Government of Canada has proposed a permanent Productivity Mega Deduction that would allow immediate expensing for most depreciable property and Canadian development expenses acquired or incurred on or after September 15, 2026. This significant tax policy change aims to reduce the marginal effective tax rate on business investment from 13% to 6.4%, though certain exclusions and restrictions apply to specific asset categories.

The Alberta government recently accelerated its plans to cut the general corporate tax rate from 10% to 8%, bringing the combined general corporate rate down to 23%.

For some reason, the lead time to the release of this year's Federal Budget seemed to really make me anxious. Since the summer of 2017 when Finance dropped the would be bomb on private corporations,

Join our panel of leading tax law experts as they examine some of the more contentious cross-border issues affecting foreign corporations doing business in Canada.

“In Prévost Car Inc. v. The Queen”, the Minister of National Revenue argued that the Canadian corporate taxpayer’s parent, a Dutch holding company, was a conduit and not the “beneficial owner” of dividends paid to it by the taxpayer.

Over the last decade the federal government has introduced legislation allowing medical doctors in Canada to incorporate.

Proposed section 143.4 of the Notice of Ways and Means Motion (NWMM) is a legislative response to the decision of the Federal Court of Appeal in Collins v. The Queen, [2012] 3 CTC 100 (FCA) (leave to appeal SCC denied 2012 CarswellNat 5845) ("Collins").

To prevent income splitting the Canadian Income Tax Act contains rules that reallocate income to a transferor in certain non arms length situations

On Wednesday, October 18, 2017, Minister of Finance Bill Morneau clarified some aspects of the Department of Finance's proposed measures to tax investment income...

Ces incitatifs fiscaux sont généralement offerts non seulement aux entreprises canadiennes, mais aussi aux investisseurs étrangers qui exercent des activités d'innovation au Canada.

As of December 10, 2016 new rules are applicable for corporations that have been dissolved in Ontario for failure to file tax returns with new deadlines within which owners may revive a dissolved corporation and recover the corporate assets.

We have a new federal Liberal government that is expected to make changes based on their election platform.