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  • Article

    Managing Remotely Raises Unique Tax Issues For Businesses

    Managing remotely raises unique tax issues for businesses.
    CanadaTax
    Torys
    Torys
  • Article

    Moodys Tax Advisors Proposes Legislation To Allow Canadians To Deduct Professional Fees Paid In IRS’s Voluntary Disclosure Programs

    Our firm, Moodys Tax Advisors, has proactively proposed legislation in Canada that will, if accepted and passed, allow a deduction against Canadian tax for the vast amount of professional fees paid to participate in the Internal Revenue Service's ("IRS's") 2011 Offshore Voluntary Disclosure Initiative ("OVDI"), the 2012 Offshore Voluntary Disclosure Program ("OVDP"), or the (traditional) Voluntary Disclosure procedure.
    CanadaTax
    Moodys Private Client Law
Moodys Private Client Law
  • Article

    Ontario Court Follows Juliar And Allows Rectification Of A Series Of Transactions

    In Canada Life, a Canadian subsidiary (Canada Life) received $3.5 billion of investment assets from its ultimate parent, which included a portfolio of U.S. dollar bonds.
    CanadaTax
    Bennett Jones LLP
    Bennett Jones LLP
  • Article

    Overview Of Proposed Changes To The Taxation Of Income Derived From Private Corporations

    In the March 2017 Federal Budget, the Department of Finance announced that it was studying certain aspects of the taxation of private corporations ...
    CanadaTax
    Dentons Canada LLP
    Dentons Canada LLP
  • Article

    Safe Income On Hand – Paying Tax Free Inter-Corporate Dividends – A Toronto Tax Lawyer Analysis

    Under Canadian tax law, corporations are able to issue dividends to certain other Canadian corporations on a tax free basis.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Section 160: The Tax Debt Trap Hiding In Plain Sight

    Section 160 of the Income Tax Act allows the CRA to hold transferees liable for a transferor's unpaid taxes when property changes hands between non-arm's length parties for less than fair market value. This provision catches not only intentional tax avoidance schemes but also ordinary family arrangements, corporate dividends, and estate planning steps that many advisers and taxpayers overlook until an assessment arrives years later.
    CanadaTax
    Robins Appleby LLP
    Robins Appleby LLP
  • Article

    Simplified Canadian Transfer Pricing Rules

    Canada's transfer pricing rules, first introduced in 1997, have historically imposed disproportionate compliance costs on smaller businesses while primarily serving large multinational enterprises. New draft regulations released in July 2026 introduce a simplified documentation regime specifically designed to reduce transfer pricing complexities for smaller Canadian businesses, while maintaining the existing penalty framework.
    CanadaTax
    Millar Kreklewetz
    Millar Kreklewetz
  • Article

    Surety Bonds Caught In Insurance Tax Net

    A recent Ontario Superior Court decision has determined that commercial surety bonds—essential tools for importers and customs brokers securing obligations with the Canada Border Services Agency...
    CanadaTax
    Millar Kreklewetz
    Millar Kreklewetz
  • Article

    Tax Court Of Canada Litigation Update "Henco Industries Limited v HMQ"

    The Tax Court of Canada decision in Henco Industries Limited v. HMQ, provides litigation and tax practitioners with guidance on evidentiary and tax issues.
    CanadaTax
    Cassels
    Cassels
  • Article

    Tax Letters: British Columbia 2016 Budget Announcement

    On February 16th, 2016, British Columbia Finance Minister Mike de Jong announced the 2016 British Columbia Budget.
    CanadaTax
    Crowe
    Crowe
  • Article

    Tax Technical Bill Receives Royal Assent

    The most significant Canadian tax technical bill in over a decade is now law, receiving royal assent on June 26, 2013.
    CanadaTax
    Osler, Hoskin & Harcourt LLP
    Osler, Hoskin & Harcourt LLP
  • Article

    Tax Traps & Tips: Beware Of Finance Bearing Gifts

    A discussion on some of the more "unexpected and unusual elements" in Finance Canada's 947-page Notice of Ways and Means Motion that are "likely to affect the provision of future income tax advice."
    CanadaTax
    DLA Piper
    DLA Piper
  • Article

    The Canadian Problem With Limited Liability Companies – A Self-Help Approach

    The administrative position of Canada Revenue Agency (CRA) with respect to U.S. limited liability companies (LLCs) has created considerable consternation. CRA consistently repeated its position that LLCs that are treated as fiscally transparent for U.S. tax purposes will not be entitled to the benefits of the Canada-U.S. Tax Convention (the Convention) on the basis that they do not qualify as residents of the U.S. for purposes of the Convention even where all the members are U.S. residents.
    CanadaTax
    Blake, Cassels & Graydon LLP
    Blake, Cassels & Graydon LLP
  • Article

    The Downside Of Tax Efficiency

    Until recently, band-owned businesses in British Columbia tended to be structured in one of three forms...
    CanadaTax
    Miller Titerle + Company
    Miller Titerle + Company
  • Article

    The Panama Papers: Canadian Bank Begins Closing Client Accounts

    Toronto Tax Lawyer Sabina Mexis discussed a CBC/Toronto Star investigation which looked into Canada's tax system...
    CanadaTax
    Devry Smith Frank LLP
    Devry Smith Frank LLP
  • Article

    The Second Anniversary Of The Disastrous Canadian Private Corporation Tax Proposals

    Today is the second anniversary of the disastrous rollout of the July 18, 2017, Canadian private corporation tax proposals.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    The Second Opinion: BCCA Finds Limited Partners Not Purchasers Of Property Sold To Limited Partnership

    When a limited partner sells property to the limited partnership, is the limited partner itself a purchaser of that property, or is the only purchaser the general partner on behalf of the limited partnership?
    CanadaTax
    McCarthy Tétrault
    McCarthy Tétrault
  • Article

    Two Percent Tax On Share Buybacks By Public Companies

    As part of the 2023 federal budget, tabled on March 28, 2023, the government has introduced draft legislation to implement a new 2% tax on share buybacks that was first announced in November 2022...
    CanadaTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    Update – Tax Measures Targeting Privately Held Corporations

    On July 18, 2017, the Department of Finance released a set of proposals to amend the Income Tax Act (the "July 18 Proposals").
    CanadaTax
    Devry Smith Frank LLP
    Devry Smith Frank LLP
  • Article

    U.S. Returns And Forms – Revised Filing Deadlines Starting For The 2016 Tax Year

    On July 31, 2015, the U.S. enacted The Surface Transportation and Veterans Health Care Choice Improvement Act, which revised the filing deadlines for certain U.S. income tax filings and foreign disclosure forms.
    CanadaTax
    Fuller Landau
    Fuller Landau
  • Showing 621–640 of 1608 results

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