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  • Article

    Canada Announces Productivity Mega Deduction

    Canada's federal government has introduced the Productivity Mega Deduction, a groundbreaking tax measure offering immediate expensing for approximately two-thirds of capital asset investments. This initiative aims to reduce Canada's marginal effective tax rate on new business investments to 6.4%, positioning it as the most competitive among G7 nations. The measure extends to Canadian Development Expenses in the energy and mining sectors, potentially transforming the economics of major capital-intensive proj
    CanadaTax
    Blake, Cassels & Graydon LLP
    Blake, Cassels & Graydon LLP
  • Article

    Canadian Income Tax – Using Family Trusts For Small Business Tax Planning – Toronto Tax Lawyer Analysis

    Although trusts are not considered a separate legal entity like corporations, they are considered separate taxpayers for the purposes of the Canadian Income Tax Act, which allows for a variety of tax planning opportunities...
    CanadaTax
Rotfleisch & Samulovitch P.C.
Rotfleisch & Samulovitch P.C.
  • Article

    Changes To The CRA Scientific Research And Experimental Development (SR&ED) Claim Form

    On October 31 2013 the CRA announced changes to the Scientific Research and Experimental Development claim form.
    CanadaTax
    MNP LLP
    MNP LLP
  • Article

    CRA Reassessment After A Tax Opinion

    A company receives a CRA reassessment after obtaining tax opinions that supported its original filing positions and transaction structures. The reassessment introduces new challenges as CRA reframes transactions...
    CanadaTax
    Counter Tax Litigators LLP
    Counter Tax Litigators LLP
  • Article

    Cross-Border Securities Lending — Still Problematic

    The ability to borrow and lend securities without significant tax consequences is essential to various capital markets activities including repo financings and hedging the obligations created by certain derivative products. U.S.-based securities lenders have traditionally faced difficulties in lending to Canadian-based securities borrowers because of potential withholding tax on payments made as compensation for dividend or interest payments on the borrowed securities.
    CanadaTax
    Blake, Cassels & Graydon LLP
    Blake, Cassels & Graydon LLP
  • Article

    Current Cases, August 2014

    The last year has provided no shortage of exciting and interesting tax cases that tax practitioners can learn from. Accordingly, the purpose of this paper is to review a select number of cases that we felt were important to highlight.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Deemed Director - When A Resignation Is Not Enough

    A director of a corporation is personally liable under subsection 323(1) of the Excise Tax Act ("ETA") for the failure of the corporation to remit goods and services tax ("GST").
    CanadaTax
    Gowling WLG
    Gowling WLG
  • Article

    Digging Deeper And Deducting Faster: What Canada’s Productivity Mega Deduction Means For Canadian Mineral Property Development

    Canada's new Productivity Mega Deduction fundamentally transforms the economics of mine development by allowing 100% immediate deductibility of Canadian development expenses incurred after September 15, 2026. How will this permanent legislative change affect project financing, flow-through share premiums, and Canada's competitive position in attracting global mining capital?
    CanadaTax
    McMillan LLP
    McMillan LLP
  • Article

    Directors’ Liability For Unremitted GST/HS

    Directors of corporations that fail to remit GST/HST may face personal liability for corporate tax debts, but statutory limitation rules create narrow windows for enforcement. The recent Stevens v. The King case demonstrates how courts scrutinize resignation claims and what evidence directors must provide to escape liability under Canada's Excise Tax Act framework.
    CanadaTax
    Millar Kreklewetz
    Millar Kreklewetz
  • Article

    Fairmont: Ont SCJ Unwinds Share Redemption And Substitutes Loan Arrangement

    The common law doctrine of rectification operates to correct mistakes in transactions that produce (or may produce) unintended and adverse tax results.
    CanadaTax
    Dentons Canada LLP
    Dentons Canada LLP
  • Article

    Fairness And Economic Substance: Select Comments On The Proposed Changes To The General Anti-Avoidance Rule

    Canada's 2023 federal budget was released on March 28, 2023 and contained proposals for changes to the general anti-avoidance rule ("GAAR").
    CanadaTax
    Miller Thomson
    Miller Thomson
  • Article

    FATCA – A Canadian Perspective / Commentary

    As many of you know, our firm has been very active in the "FATCA" space.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Federal Court Of Appeal Affirms Application Of Subsection 84(2) Of The Income Tax Act (Canada) To A Hybrid Business Sale Transaction

    In the context of a sale of a business operated by a corporation, the seller and buyer typically have competing interests. Whereas sellers tend to prefer selling their shares of the corporation...
    CanadaTax
    Miller Thomson
    Miller Thomson
  • Article

    Foreign-Based Information

    Tax executives and practitioners familiar with administrative procedures under the Canadian <I>Income Tax Act</I> (the "Act") are aware of the broad powers afforded the Canada Customs and Revenue Agency ("CCRA") to conduct audits, to compel the production of books and records and even to obtain and execute search warrants
    CanadaTax
    Blake, Cassels & Graydon LLP
    Blake, Cassels & Graydon LLP
  • Article

    Further Commentary By Canada Revenue Agency On Paragraph 149(1)(l) – Profit Motive And Distribution Of Income To Members

    Canada Revenue Agency has recently released Document 2012-0455501I7 on whether certain transactions and investments jeopardized a corporation’s tax exempt status as a not-for-profit organization under paragraph 149(1)(l) of the Income Tax Act.
    CanadaTax
    Gowling WLG
    Gowling WLG
  • Article

    House Republicans Moving Forward On U.S. Tax Reform

    After many promises and surprising secrecy, House Republicans took a significant step toward enacting transformative federal tax legislation on November 2, 2017.
    CanadaTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    Important Changes To US Tax Filing Deadlines For Canadians

    Under prior law, the filing deadline for US corporations (that is, corporations subject to the US corporate income tax), was the fifteenth day of the third month following the end of the taxable year.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Joint Debt – A Matter of Form

    Where there is a financing of a multinational group of affiliated corporations, it is becoming more common to have the indebtedness issued by several of the affiliated corporations as co-issuers, in which case there are various tax issues to address.
    CanadaTax
    Blake, Cassels & Graydon LLP
    Blake, Cassels & Graydon LLP
  • Article

    Legislative Proposals Confirm SR&ED Changes

    In the 2012 federal budget, the Department of Finance (Finance) announced a number of measures that reduce the benefits available under the Scientific Research and Experimental Development (SR&ED) tax incentive program.
    CanadaTax
    PwC Management Services LP
    PwC Management Services LP
  • Article

    Ontario Phase-Out Of Recaptured Input Tax Credits

    The requirement for certain large businesses to recapture the provincial portion of Ontario HST claimed as Input Tax Credits (ITCs) in respect of specified property and services will be phased out, starting July 1, 2015.
    CanadaTax
    Kestenberg Rabinowicz Partners LLP
    Kestenberg Rabinowicz Partners LLP
  • Showing 721–740 of 1610 results

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