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Article
IRS Proposes Broad Limit On Intercompany Debt
The Internal Revenue Service has proposed new regulations that would generally treat intercompany indebtedness in corporate groups with 80% common ownership as equity for U.S. tax purposes.
CanadaTax
Davies Ward Phillips & Vineberg LLP
Article
Just In Time For Legalization, Federal Government Publishes Proposed Cannabis Excise Duty Rates
The federal government recently gave royal assent to the Budget Implementation Bill, 2018, No. 1, which amends the Excise Act, 2001 in order to implement a new framework for the taxation of cannabis.
CanadaTax
Blake, Cassels & Graydon LLP

Loss Of U.S. Compensation Deduction As IRS Narrows View On “Performance-Based” Exception

US compensation deductions for certain payments are threatened by a recent IRS position that reverses a long-standing interpretation that certain bonuses arrangements qualify for an exception to Code Section 162(m)’s deduction limitation for “performance-based” compensation.

Osler, Hoskin & Harcourt LLP

Morguard Corp. v. R.

In the recent decision Morguard Corp. v R., 2012 TCC 55, the Tax Court of Canada considered the proper tax treatment of a break fee in the hands of a recipient as a result of a failed takeover bid.

New Bank Of Israel Directive Is Prompting Canadian Taxpayers To Bring Their Tax Affairs In Order

The Bank of Israel has recently implemented measures that are designed to minimize legal and reputational risks for Israeli banks.

Borden Ladner Gervais LLP

New Considerations When Seeking To Multiply Access To The Lifetime Capital Gains Exemption

Proactive planning to multiply access to the lifetime capital gains exemption ("LCGE") for shares of a qualified small business corporation ("QSBC") or qualified family farm property...

Now's A Good Time To Think About RRSPs

A good way to begin is by taking stock of the past year.

Lawyers Financial

Ontario's New HST Rebate: Key Details

Ontario government announced a full HST rebate for new homes up to $1 million, with a maximum rebate of $130,000.

Osler, Hoskin & Harcourt LLP

Parliament Passes Friendly Tax Changes For Farms And Small Businesses

On June 23, 2021, the Senate of Canada passed Bill C-208 without amendment. The final formal step is for the Bill to receive Royal Assent, at which point the amendments will become law...

Québec Budget 2016-2017 Announces Changes To Transfer Duties

The Québec 2016-2017 Budget delivered on March 17 announced a number of important changes to the province's land transfer duty regime.

McCarthy Tétrault

Representation And Warranty Insurance In Canadian Technology M&A Transactions: What Risks Are Insurers Looking For? Part III: Tax Risks

Representation and Warranty Insurance (RWI) is an increasingly important tool for managing transactional risk in technology-sector M&A.

Stikeman Elliott LLP

Restrictive Covenant Rules – Good News Update!

On July 28, 2014, we published a blog that discussed a recent Canada Revenue Agency announcement at the 2014 Society of Trust and Estate Practitioners Roundtable.

Moodys Private Client Law

Roitelman: Director Not Liable Where Employee Engages In Deceit

Can a director establish a due diligence defence with respect to unremitted source deductions where the responsibility for remittance lay with an employee?

Bennett Jones LLP

Simplification Of Tax On Split Income Rules

On December 13, 2017, the Department of Finance introduced revised rules relating to distributions of income (referred to as "income sprinkling") from a private corporation.

Dentons Canada LLP

Staffing Agencies Caught By EHT!

As discussed here, our recent file experience demonstrates that provincial governments, like Ontario's Ministry of Finance ("MOF"), are ramping up audits for Employer Health Tax ("EHT") liability.

Millar Kreklewetz

Tax Exemptions For Non-Profit Organizations

Canada Revenue Agency conducts an annual review to see how organizations which claim the tax exemption under paragraph 149 (1) (l) of the Income Tax Act operate.

Tax Risks From Underground Banks: Toronto Tax Lawyer Analysis

Canada has been criticized for failing to police and control the growth of underground currency exchange and banking networks in Toronto.

Rotfleisch & Samulovitch P.C.

Taxing Virtual Money: The Bitcoin And The CRA

New business remains subject to the old taxes. Believing otherwise is wishful thinking. The latest tax topic in the world of technology is the Bitcoin.

Dale & Lessmann LLP

Ten Things We Learned From The Tax Announcements

Those of us following the Government of Canada's proposed tax changes since mid-July, experienced quite the wild ride last week.

Crowe Soberman LLP

The Checkup: 2020 Edition

The 2020 issue of our annual newsletter, The Checkup, is now available for download.

Crowe Soberman LLP

Showing 601–620 of 3220 results

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