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  • Article

    The Québec 2016-2017 Budget Introduces An Innovative Companies Deduction

    Last week's announcement of Québec's 2016-2017 Budget included an exciting new tax relief initiative for qualifying innovative Québec manufacturing corporations.
    CanadaIntellectual Property
    Smart & Biggar
    Smart & Biggar
  • Article

    Doing Business In Canada

    There are many reasons for wanting to do business in Canada including the availability of a skilled workforce, low corporate tax rates, abundant natural resources and a stable political system and economy.
    CanadaInternational Law
    Borden Ladner Gervais LLP
    Borden Ladner Gervais LLP
Article

1057513 Ontario Inc.: The Clear Meaning Of Subsection 129(1)

At the heart of tax integration in Canada is the refundable tax and dividend refund mechanism in subsection 129(1) of the Income Tax Act (the "Act").
CanadaTax
Dentons Canada LLP
Dentons Canada LLP
  • Article

    A Primer On ABIL Claims: Part I

    This article will be the first in a series of articles that discuss the Allowable Business Investment Loss ("ABIL"), including the interpretation of key terms as well as a discussion of recent case law.
    CanadaTax
    Miller Thomson
    Miller Thomson
  • Article

    Alberta Budget 2019: The Return of the "Alberta Advantage"

    The release of the 2019 Alberta Budget has signaled that Premier Jason Kenney remains committed to bringing back the "Alberta Advantage" by returning to broad-base low corporate tax rates.
    CanadaTax
    Stikeman Elliott LLP
    Stikeman Elliott LLP
  • Article

    Breaking Down Changes To The Small Business Deduction

    In Canada, corporations may claim a small business deduction on their corporate tax returns, effectively reducing the corporate tax rate on the first $500,0001 of taxable income from active business income.
    CanadaTax
    Collins Barrow National Incorporated
    Collins Barrow National Incorporated
  • Article

    British Columbia 2017 Budget Update

    On September 11th, 2017, British Columbia Finance Minister Carole James provided a British Columbia Budget update. Below is a summary of some of the tax and other measures announced in the update.
    CanadaTax
    Crowe
    Crowe
  • Article

    Business Income Tax Measures

    Budget 2013 proposes to introduce a new rule to target what the Government describes as a form of corporate loss trading.
    CanadaTax
    Osler, Hoskin & Harcourt LLP
    Osler, Hoskin & Harcourt LLP
  • Article

    Canadian Government Proposes Major Changes To The Taxation Of Private Corporations

    The Canadian Department of Finance released a discussion paper earlier today on tax planning using private corporations.
    CanadaTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    Changes To The Income Tax Act Place New Risks On Intercorporate Dividends

    Intercorporate dividends are traditionally a very common tool for tax planning.
    CanadaTax
    McLennan Ross LLP
    McLennan Ross LLP
  • Article

    CRA Challenges Whether Netherlands Holding Company Is “Beneficial Owner” Of Dividends

    In a case argued in the Tax Court of Canada in September 2007 but not yet decided (Prevost Car Inc. v. The Queen, the Canada Revenue Agency (the CRA) has taken the position that a Netherlands holding company was not the “beneficial owner” of dividends paid to it by its Canadian subsidiary.
    CanadaTax
    Blake, Cassels & Graydon LLP
    Blake, Cassels & Graydon LLP
  • Article

    Demystifying Par Value Shares: Tax Advisors Beware

    Par value shares are often considered one of the last vestiges of the old Canadian corporate legislation. The current federal corporate legislation, and the majority of provincial...
    CanadaTax
    Miller Thomson
    Miller Thomson
  • Article

    Draft Technical Amendments Expand The Scope Of Taxable Canadian Property

    The Canadian government has proposed significant technical amendments to the Income Tax Act's definition of "taxable Canadian property" (TCP), fundamentally altering how publicly traded partnership units are classified and expanding the look-through rules for determining TCP status. These changes, effective upon Royal Assent, will impact cross-border transactions and investment structures by broadening the scope of what constitutes TCP and reinstating historical rules for options and interests in property.
    CanadaTax
    Borden Ladner Gervais LLP
    Borden Ladner Gervais LLP
  • Article

    Dues And Don’ts: What Health Professionals Can And Cannot Deduct From Their Taxes

    Regulated health professionals are likely quite familiar with the annual dues that are imposed upon them by their regulatory college in order to maintain their practice within the profession. However, they may be less familiar with the deductibility of these dues when filing their annual taxes.
    CanadaTax
    MLT Aikins LLP
    MLT Aikins LLP
  • Article

    Federal Court of Appeal Allows GAAR Appeal in Lehigh

    On May 17, 2010, the Federal Court of Appeal delivered its unanimous decision, (see attached), allowing the taxpayer’s appeal in Lehigh Cement Limited.
    CanadaTax
    Osler, Hoskin & Harcourt LLP
    Osler, Hoskin & Harcourt LLP
  • Article

    Foundations Of Business Valuation: What Is Maintainable?

    A business that is considered to be economically viable is generally valued on a going concern approach implying that the business will continue to operate into the future.
    CanadaTax
    Duff & Phelps
    Duff & Phelps
  • Article

    Full Speed Ahead: What Canada's New Immediate Expensing Means For Manufacturers

    If your business has been considering expanding production, upgrading equipment, or building new facilities...
    CanadaTax
    Miller Thomson
    Miller Thomson
  • Article

    Further Elimination Of The Small Business Tax Deferral

    Ontario corporations are subject to a general corporate income tax rate of 26.5%
    CanadaTax
    Collins Barrow National Incorporated
    Collins Barrow National Incorporated
  • Article

    Highlights From The Québec Government's 2013-2014 Budget Relating To Businesses

    Under this new program, corporations and partnerships that begin to carry out a large investment project in Québec after November 20, 2012 may, under certain circumstances, obtain a ten-year tax holiday.
    CanadaTax
    McCarthy Tétrault
    McCarthy Tétrault
  • Article

    Just A Spoonful Of TOSI May Help The Medicine Go Down

    The Department of Finance released its long-awaited proposed amendments to the tax on split income (TOSI) rules on December 13.
    CanadaTax
    Collins Barrow National Incorporated
    Collins Barrow National Incorporated
  • Showing 601–620 of 1608 results

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