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  • Article

    The TaxLetter: The Prescribed Loan - The 1% Is Back

    So far, 2020 has been quite a downer - and not just emotionally, but also economically. So it was only a matter of time before the CRA announced a drop in the prescribed rate.
    CanadaTax
    Minden Gross LLP
    Minden Gross LLP
  • Article

    The Year In Review- An Annual Publication Of The ABA/Section Of International Law: International Tax 2021

    Our partner Sunita Doobay - Co-Chair of the International Tax Committee of the Section of International Law of the American Bar Association (ABA) – contributed to the ABA 2021 Year In Review.
    CanadaTax
    Blaney McMurtry LLP
    Blaney McMurtry LLP
Article

Time To Restructure: Canadian ULC Structures Adversely Affected By Amended Canada-US Tax Treaty

The Canada-US Income Tax Convention (Canada-US Treaty) was recently amended to include a so-called hybrid denial rule. This rule will adversely affect Canada-US cross-border structures involving Canadian unlimited liability companies (ULC).
CanadaTax
McCarthy Tétrault
McCarthy Tétrault
  • Article

    Towards A Global FATCA?: OECD, G20 Unanimously Endorse Global Automatic Information Exchange

    This global automatic information exchange initiative is based on each jurisdiction’s participation in the OECD’s Multi-lateral Convention on Mutual Administrative Assistance in Tax Matters.
    CanadaTax
    MNP LLP
    MNP LLP
  • Article

    Cryptocurrency: The CRA Breaks Its Silence

    In our prior update entitled Cryptocurrencies and Tax: Five Things Every Canadian Needs to Know, we explained the CRA views on the taxation of cryptocurrency...
    CanadaTechnology
    Wildeboer Dellelce LLP
    Wildeboer Dellelce LLP
  • Article

    Deduction Of Home Office Expenses For Employees Required To Work From Home

    Months into COVID lockdown with no near end in sight, employers continue to encourage employees to work from home and seek opportunities to offer financial relief to their employees.
    CanadaCoronavirus (COVID-19)
    Borden Ladner Gervais LLP
    Borden Ladner Gervais LLP
  • Article

    2016 Federal Budget – Impact on Registered Charities and Non-Profit Organizations

    The Minister of Finance tabled the Government's 2016 Federal Budget on March 22, 2016.
    CanadaCorporate/Commercial Law
    Borden Ladner Gervais LLP
    Borden Ladner Gervais LLP
  • Article

    SCA Decides On The Deductibility Of Raising Fees As 'Similar Finance Charges' Under Section 24J

    ‘Interest’ is deductible in terms of section 24J(2) of the Income Tax Act. The term ‘interest’ is defined to include any interest ‘or similar finance charges’. The meaning of ‘similar finance charges’ has been uncertain since the 2016 amendment replaced the broader expression ‘related finance charges’ with ‘similar finance charges’. Under the previous wording, the SCA held in CSARS v South African Custodial Services that various costs closely connected to obtaining finance, including guarantee, advisory, margin, commitment, legal and administration fees, qualified as ‘related finance charges’.
    CanadaFinance and Banking
    Fasken
    Fasken
  • Article

    2007 Budget - Capital Gains Exemption Clarification

    The March 19, 2007 Federal Budget ("Budget") introduced proposals to increase the capital gains exemption from $500,000 to $750,000.
    CanadaTax
    Gowling WLG
    Gowling WLG
  • Article

    Canada Clarifies And Expands Proposal For Equity Buyback Tax

    In November 2022, we wrote about the federal government's proposal in the 2022 Fall Economic Statement to tax share buybacks by public corporations in our blog, Canada Proposes New...
    CanadaTax
    Bennett Jones LLP
    Bennett Jones LLP
  • Article

    Canada Federal Budget 2025

    On November 4, 2025, the federal government introduced Canada Strong: Budget 2025 ("Budget 2025"), the first tabled by the Liberals under Prime Minister Mark Carney's leadership.
    CanadaTax
    Dentons Canada LLP
    Dentons Canada LLP
  • Article

    Canadian And U.S. Tax Laws: A Review Of 2017 And A Look Ahead To 2018

    The year 2017 was eventful from both Canadian and U.S. tax perspectives. In Canada, the Liberal government introduced new rules on income splitting and released controversial proposals on the taxation...
    CanadaTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    Canadian Fall Economic Statement Regarding Tax Treatment Of Employee Stock Options

    In the 2019 federal budget, the Canadian federal government announced changes to the taxation of employee stock options. On November 30, 2020, in its Fall Economic Statement, the federal...
    CanadaTax
    Dickinson Wright PLLC
    Dickinson Wright PLLC
  • Article

    Canadian Federal Budget Proposes To Cap Employee Stock Option Benefit

    New legislation proposed in the 2019 Federal Budget would limit the extent to which employees will be entitled to favourable Canadian income tax treatment on certain stock options.
    CanadaTax
    Dickinson Wright PLLC
    Dickinson Wright PLLC
  • Article

    Canadian Tax Facts 2025

    Every year, people need to update themselves on the tax facts of the country where they live or own a business.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Capital Gains Tax Rate Changes: A Clearer Picture For Taxpayers

    On January 31, 2025, the Minister of Finance of Canada announced that the federal government is deferring the proposed date on which the capital gains inclusion rate would increase from one-half to two-thirds on capital gains realized annually above $250,000 by individuals and on all capital gains realized by corporations and most types of trusts.
    CanadaTax
    MLT Aikins LLP
    MLT Aikins LLP
  • Article

    CRA Tax Return Statistics For The 2016 Personal Tax-Filing Season

    The Canada Revenue Agency has released information about the 2006 T1 tax return filing season.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Department Of Finance Clamps Down On Stapled Securities

    The Department of Finance announced this morning that it will amend the Income Tax Act (Canada) (the "Tax Act") in response to certain transactions involving "stapled securities" that it considers to be end runs around its efforts to tax income trusts.
    CanadaTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    "FBAR" Reporting Obligations For U.S. Executives Of Canadian Companies Sometimes Overlooked

    United States citizens and "green card" holders who live abroad have long been subject to U.S. tax reporting obligations.
    CanadaTax
    Torys
    Torys
  • Article

    Government Of Canada Reverses Course: Deferral Of The Increase To Capital Gains Inclusion Rate To January 1, 2026

    In a welcome development for taxpayers, the Department of Finance ("Finance") announced on January 31, 2025 (the "Announcement") that it would defer the implementation of the proposed...
    CanadaTax
    Miller Thomson
    Miller Thomson
  • Showing 401–420 of 5652 results

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