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  • Article

    Tax Season — More Than Just A Filing Process - Opportunities To Enhance Your Corporate Structure

    Spring is upon us and our thoughts turn toward spring flowers, warm evening walks, barbecues and doing taxes.
    CanadaTax
    Ernst & Young
    Ernst & Young
  • Article

    What You Need To Know About American State Tax Nexus

    It's no secret that since the financial market meltdown of 2008, state governments have been looking to increase revenues by stepping up efforts to find non-compliant domestic and foreign taxpayers through state tax nexus requirements.
    CanadaTax
    Fuller Landau
    Fuller Landau
Article

“Prévost Car”: Dutch Intermediary Is “Beneficial Owner” Under Treaty

In “The Queen v. Prévost Car Inc.”, the Federal Court of Appeal dismissed the Minister of National Revenue’s appeal from the Tax Court’s decision that the Canadian corporate taxpayer’s parent, a Dutch holding company, was the “beneficial owner” of dividends which entitled it to a reduction in the 25% rate of Canadian non-resident withholding tax to 5% under Article 10(2) of the “Canada- Netherlands Income Tax Convention” (the “Treaty”).
CanadaTax
Borden Ladner Gervais LLP
Borden Ladner Gervais LLP
  • Article

    The Biggest Shake-Up In International Tax Rules In A Generation Is Here

    On October 5, the Organisation for Economic Co-operation and Development (OECD) unveiled its comprehensive action plan to combat base erosion and profit shifting (BEPS).
    GlobalTax
    Grant Thornton
    Grant Thornton
  • Article

    Ontario Superior Court Clarifies Surety Bond Fees Subject To 3% Premium Tax Under The Corporations Tax Act

    The Ontario Superior Court has ruled that fees received by insurers for surety products written in Ontario are subject to the 3% premium tax under the Corporations Tax Act. This decision clarifies the tax treatment of surety bonds by interpreting ambiguous statutory language through reference to federal Income Tax Act provisions and legislative history. Insurers licensed to write surety business in Ontario should review their premium-tax reporting practices in light of this ruling.
    CanadaInsurance
    Gowling WLG
    Gowling WLG
  • Article

    2015 Election Results: What The Liberal Tax Platform Could Mean For You And Your Business

    With the election of a majority Liberal government on October 19, there's no doubt that we will see a number of tax changes over the next four years.
    CanadaTax
    Grant Thornton
    Grant Thornton
  • Article

    2016 Saskatchewan Budget Summary

    The 2016-17 budget continues to invest in health care, education and social services. It also provides more than $3.5 billion for investment in infrastructure.
    CanadaTax
    Grant Thornton
    Grant Thornton
  • Podcast

    Episode 028 – 2023 Federal Budget Predictions (Podcast)

    In this episode of TaxBreaks, Kenneth Keung and Kim GC Moody provide their predictions on what might be included – or not – in the 2023 Canadian Federal Budget...
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    It's A Matter Of Trust – Part II

    This discussion is a continuation of our earlier Tax Alert and will focus on selected traps that taxpayers should be aware of when undertaking tax planning involving trusts.
    CanadaTax
    Collins Barrow National Incorporated
    Collins Barrow National Incorporated
  • Article

    OECD Report Proposes New Treaty Shopping Rules

    In February we wrote about a discussion draft of Action 6 of the Action Plan on Base Erosion developed by the Organisation for Economic Co-Operation and Development at the request of the G20.
    CanadaTax
    Norton Rose Fulbright Canada LLP
    Norton Rose Fulbright Canada LLP
  • Article

    Ontario Small Business Income Tax Relief Ahead Of The Minimum Tax Wage Increase

    Ontario Minister of Finance Charles Sousa announced a reduction to the small business tax rate to take effect on January 1, 2018.
    CanadaTax
    Collins Barrow National Incorporated
    Collins Barrow National Incorporated
  • Article

    5 Succession Planning Tips

    A solid company succession plan not only helps you sleep nights; it's also a retention and motivation tool.
    CanadaCorporate/Commercial Law
    Fuller Landau
    Fuller Landau
  • Article

    Mark It On The Calendar: Key Dates And Tasks For Alberta Corporations

    Running a corporation in Alberta involves juggling numerous administrative tasks and deadlines. Missing any of these crucial dates can lead to significant legal and financial repercussions.
    CanadaCorporate/Commercial Law
    Reynolds Mirth Richards & Farmer
    Reynolds Mirth Richards & Farmer
  • Article

    The Government Of Québec Unveils Proposals To Preserve Head Office Jobs In The Province

    On February 20, 2014, the government of Québec tabled its 2014-2015 budget in which it stated that it may enact amendments to Québec’s Business Corporations Act intended to protect Québec incorporated businesses from unsolicited take-over bids, as well as tax incentives intended to encourage businesses to establish and maintain head offices in the province of Québec.
    CanadaCorporate/Commercial Law
    Osler, Hoskin & Harcourt LLP
    Osler, Hoskin & Harcourt LLP
  • Article

    Canadian Transfer Pricing Developments Multinationals Should Know About

    Prompted by government concerns about the depletion of Canada’s tax base, tax authorities here are now using transfer pricing principles as a primary audit tool to evaluate – and challenge – income allocation to Canada by multinationals. As a result, virtually all cross-border business activities between related parties are now subject to transfer pricing audits. Here, we look at some of the key areas tax authorities are zeroing in on.
    CanadaFinance and Banking
    Osler, Hoskin & Harcourt LLP
    Osler, Hoskin & Harcourt LLP
  • Article

    The New Alberta Government's First Speech From The Throne

    On Monday, June 15, 2015, Alberta's newest Lieutenant Governor, Her Honour Lois Mitchell, C.M., delivered the Speech from the Throne, kicking off the First Session of the 29th Legislature of Alberta.
    CanadaGovernment, Public Sector
    Borden Ladner Gervais LLP
    Borden Ladner Gervais LLP
  • Article

    B.C. Government Announces Next Steps In #BCTECH Strategy To Bolster Technology Sector

    The third strategic pillar of increasing the access of technology companies to markets is an important forward-looking step towards sustainability.
    CanadaMedia, Telecoms, IT, Entertainment
    Blake, Cassels & Graydon LLP
    Blake, Cassels & Graydon LLP
  • Article

    M&A Tax Trends

    In our "M&A Outlook for 2012", we discussed the emergence, in 2011, of foreign asset income trusts and noted that we expected the trend to continue in 2012.
    CanadaTax
    Stikeman Elliott LLP
    Stikeman Elliott LLP
  • Article

    OECD's Global Tax Reform 2021

    In connection with the OECD's Base Erosion and Profit Shifting Project, a group of 140 countries have made commitments to radically modify the international tax system.
    CanadaTax
    Gardiner Roberts LLP
    Gardiner Roberts LLP
  • Article

    Sell Now! (How the 2014 Budget May Impact on Business Owners' Exit Strategies)

    The federal government's 2014 Budget contained a host of changes, including "proposals" to change the taxation of eligible capital property (i.e., goodwill, patents, trademarks, intellectual property, etc.) so that it will be taxed in the same way that gains on other depreciable capital property (e.g. equipment, commercial vehicles, etc.) are taxed.
    CanadaTax
    Minden Gross LLP
    Minden Gross LLP
  • Showing 401–420 of 1608 results

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