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  • Article

    Taxation Of Investment Income; Voluntary Disclosure Program and Automatic Exchange Of Tax Information

    Taxation Of Investment Income; Voluntary Disclosure Program and Automatic Exchange Of Tax Information
    CanadaTax
    Gardiner Roberts LLP
    Gardiner Roberts LLP
  • Article

    Taxpayer Wins Interest Deductibility Case At Federal Court Of Appeal: The TDL Group Co. v. The Queen, 2016 FCA 67

    Although not mentioned in the reasons from the FCA, the ultimate purpose of these transactions was to fund a long-term expansion of Tim Hortons in the U.S.
    CanadaTax
    Osler, Hoskin & Harcourt LLP
    Osler, Hoskin & Harcourt LLP
Article

The 100% Solution

Recent announcement clarifies grandfathering rules for Canadian income trusts.
CanadaTax
Stikeman Elliott LLP
Stikeman Elliott LLP
  • Article

    The Federal Court Of Appeal Permits Use Of Mark-To-Market Tax Accounting

    The Federal Court of Appeal has held in the Kruger Inc. v. Canada decision published yesterday, that Kruger Inc. was entitled to use the mark-to-market method in computing its income for federal income tax purposes.
    CanadaTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    The Future Of Canada Revenue Agency Enforcement Activities

    As noted in an earlier blog post, we discussed the joint CBC / Toronto Star investigation and subsequent release of the Panama Papers.
    CanadaTax
    Devry Smith Frank LLP
    Devry Smith Frank LLP
  • Article

    The Proposed Residential Property Flipping Rule

    For instance, a taxpayer might sell her condominium in order to purchase a home with her fiancé.
    CanadaTax
    SpenceDrake Tax Law
    SpenceDrake Tax Law
  • Article

    The Tax Benefits Of A Personal Real Estate Corporation

    There have been many discussions recently about the ability for real estate agents to now incorporate themselves, including a recent article penned by my colleagues.
    CanadaTax
    Minden Gross LLP
    Minden Gross LLP
  • Article

    Transfer Pricing Disputes: How Forum Choice Alters Outcomes

    When the SCC confirmed that discretionary denials under s. 247(10) fall outside the Tax Court's jurisdiction, MEGLobal's appeal was effectively doomed.
    CanadaTax
    Counter Tax Litigators LLP
    Counter Tax Litigators LLP
  • Article

    Trustees Alert: Brace For Potential First-Time Filings In 2024!

    The Canada Revenue Agency (CRA) has implemented significant changes to trust reporting rules for taxation years ending after December 30, 2023.
    CanadaTax
    Dale & Lessmann LLP
    Dale & Lessmann LLP
  • Article

    Update On Finance Proposals: Some Good, Some Bad

    During the summer, the Department of Finance issued sweeping tax proposals ("Proposals") targeted at private businesses.
    CanadaTax
    Torkin Manes LLP
    Torkin Manes LLP
  • Article

    Update –- Alberta Unlimited Liability Corporations

    Amendments to the Business Corporations Act (Alberta) (the ABCA) providing for the incorporation of unlimited liability corporations are now law. Those amendments also include several other provisions of particular interest to tax practitioners such as changes to the corporate incest rule and the share dividend provisions.
    CanadaTax
    Blake, Cassels & Graydon LLP
    Blake, Cassels & Graydon LLP
  • Article

    Urgent Advisory: Commence Voluntary Disclosures Before The End Of 2015

    Data from the Canada Revenue Agency ("CRA") confirms that voluntary disclosures ("VDs") of offshore assets, gains and income hit record levels in 2015.
    CanadaTax
    Gowling WLG
    Gowling WLG
  • Article

    US Insurers Have No PE In Canada

    On May 16, 2008, the Tax Court of Canada released its judgments in American Income Life Insurance Company v. The Queen and Knights of Columbus v. The Queen.
    CanadaTax
    Borden Ladner Gervais LLP
    Borden Ladner Gervais LLP
  • Article

    U.S. Internal Revenue Service To End Offshore Voluntary Disclosure Program

    On March 13, 2018 the U.S. Internal Revenue Service (IRS) announced it will be shutting down the Offshore Voluntary Disclosure Program (OVDP) in September.
    CanadaTax
    MNP LLP
    MNP LLP
  • Article

    What If Your Voluntary Disclosure Is Denied? Second Administrative Review & Judicial Review

    Canada Revenue Agency's (CRA) voluntary disclosure program provides a taxpayer (e.g., an individual or corporation) with a one-time opportunity to retroactively comply with Canadian tax law.
    CanadaTax
    SpenceDrake Tax Law
    SpenceDrake Tax Law
  • Podcast

    Why Your Income For Taxes May Not Be Your Income For Child Support (or Spousal Support) (Podcast)

    Podcast #76 – Why Your Income for Taxes May Not Be Your Income for Child Support (or Spousal Support...
    CanadaTax
    Devry Smith Frank LLP
    Devry Smith Frank LLP
  • Article

    Trade-marks And The Québec Charter Of The French Language

    CanadaTransport
    Gowling WLG
    Gowling WLG
  • Article

    The CRA Has Simplified The Process For Employees To Claim A Tax Deduction For Working From Home Due To COVID-19

    In 2020, as offices and workplaces across Canada closed or reduced staffing capacity due to COVID-19, many Canadian workers who normally performed work at their employer's worksite were suddenly required to work from home, either fully or partially.
    CanadaCoronavirus (COVID-19)
    Lawson Lundell LLP
    Lawson Lundell LLP
  • Article

    Bare Trusts: An Overview Of Canada's New Filing Requirements Ahead Of The 2023 Taxation Year

    This income tax season will look different for Canadian trusts: the Government of Canada has implemented new filing requirements that are applicable to trusts.
    CanadaCorporate/Commercial Law
    Bishop & McKenzie LLP
    Bishop & McKenzie LLP
  • Article

    Can Canadian Courts Turn To Religious Documents In A Religious Dispute?

    You will want to know about the recent Ontario Court of Appeal decision in Pankerichan v Djokic, if you are part of a religious community which is considering or is in the midst of the following...
    CanadaCorporate/Commercial Law
    Borden Ladner Gervais LLP
    Borden Ladner Gervais LLP
  • Showing 521–540 of 5652 results

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