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The Canada Revenue Agency ("CRA") has released updated Information Circular IC72-17R6 dated September 29, 2011, replacing IC72-17R5 (March 15, 2005).

Section 88 of the Income Tax Act (Canada) (the "Tax Act") applies on an acquisition of control of one taxable Canadian corporation (the "Subsidiary") by another taxable Canadian corporation (the "Parent") to permit the Parent to increase (or "bump") the tax cost of certain assets owned by the Subsidiary at the time of the acquisition of control upon a subsequent winding-up of the Subsidiary into, or a vertical amalgamation of the Subsidiary with, the Parent.

The proposed amendments to the DRA Rules, if enacted, will apply to dividends that are paid or become payable after October 2015.

The thin capitalization rules limit the ability of a Canadian corporation to deduct interest paid to a non-resident parent, a non-resident affiliate and certain other non-residents.

The Federal Court of Appeal has once again affirmed the importance of Generally Accepted Account Principles (GAAP) in computing liability for the large corporation tax (LCT) applicable prior to 2006 while rejecting the Crown’s economic substance argument: The Queen v. Bombardier Inc.

In Ontario, there are preferential tax rates that apply to a corporation's profits when certain criteria are met. One of the more compelling circumstances that Canadian corporation...

The 2009 Ontario Budget, tabled on March 26, sets out a proposal to harmonize Ontario’s provincial sales tax with the Federal goods and services tax effective July 1, 2010. Ontario will become the fifth province to bring its sales tax in line with the GST (Newfoundland, New Brunswick, and Nova Scotia have harmonized sales taxes, while Québec’s provincial sales tax is parallel to the GST, but is separately administered).

Dividends, on the other hand, may cost the family unit less in current taxes.

In preparation for the implementation of the LNG income tax in British Columbia starting in 2017, the Government of British Columbia has now established a website to provide more detailed information...

Recent Federal Court of Appeal jurisprudence demonstrates that unsuccessful tax litigants must generally pay the government's legal costs regardless of financial difficulties, while successful litigants may still face cost awards due to procedural rules. Understanding the discretionary nature of cost awards in Tax Court of Canada proceedings is critical, as variables ranging from settlement offers to case complexity can significantly impact who pays legal bills.

Nobody likes to pay too much tax. Luckily, there are a number of tax-saving measures that can help with just that—both for businesses and individuals.

As we have previously reported in our update on the 2024 Federal Budget ("Budget 2024"), the Department of Finance announced a proposed increase to the capital gains...

Just over a year ago, Budget 2017 announced that the Government was reviewing the taxation of private corporations.

Bill C-31, Canada's Budget 2025 Implementation Act No. 2, is currently before Parliament's Finance Committee with significant amendments to indirect tax rules. The legislation proposes to double the Tax Court's informal procedure threshold for GST appeals to $100,000, clarify tax treatment for credit unions, and modify imported supply rules for financial institutions dealing with insurance policies and loans connected to Canada.

In Canada, dividends, interest, royalties and certain other payments paid to non-residents are subject to 25% withholding tax on the gross amount pursuant to the <I>Income Tax Act</I> (Canada) (the Act). Under most of Canada’s tax treaties, including the Canada-U.S. Tax Convention (the US Treaty) and the Canada-U.K. Tax Convention (the UK Treaty), the withholding rate is reduced on payments to persons who are residents of the U. S. or the U.K., respectively for purposes of the US Treaty or the U

The Canada Revenue Agency (CRA) has recently issued an administrative income tax ruling which expands the possible application of the "5/25" Canadian withholding tax exemption for interest paid by Canadian corporate borrowers, by blessing for the second time a back-to-back loan arrangement. The ruling confirms that the general anti-avoidance rule (GAAR) would not be applied to deny the exemption in the circumstances presented.

On March 29, 2022, the Government of Canada delivered its 2030 Emissions Reduction Plan (the 2030 ERP), Canada's first-issued emissions reduction plan under the Canadian Net-Zero...