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  • Article

    What Estate Tax Liabilities Do Advisors And Clients Need To Stay Aware Of ?

    The fact that we don't have an estate tax in Canada can be both a comfort and a hindrance in some estate plans. While no explicit estate tax is imposed upon death...
    CanadaTax
    Robins Appleby LLP
    Robins Appleby LLP
  • Article

    When CRA Scrutiny Shifts From Mechanics To Interpretive Requirements

    D'Arcy v. HMK shows that meeting mechanical requirements is not enough; interpretive precision determines whether a structure holds under scrutiny.
    CanadaTax
    Counter Tax Litigators LLP
    Counter Tax Litigators LLP
Video

2021 Taxation Of Tech Outlook: Trends For Outbound M&A (Video)

Curious about new developments in the taxation of tech? This engaging webinar brings together a panel of tax experts from Canada, the UK, France, Mexico and the US to discuss current and upcoming trends...
GlobalTax
Gowling WLG
Gowling WLG
  • Article

    Whistleblowing Pays Off—New CRA Data On First Payments To Informants

    The Canada Revenue Agency's (CRA) Offshore Tax Informant Program (OTIP) is a whistleblower program that rewards eligible individuals who come forward to provide CRA with information
    CanadaEmployment and HR
    Bennett Jones LLP
    Bennett Jones LLP
  • Article

    The Cross-Border Quarterly Report

    The Cross-Border Quarterly Report is a snapshot of transactional activity across the Canada-U.S. border.
    CanadaFinance and Banking
    Osler, Hoskin & Harcourt LLP
    Osler, Hoskin & Harcourt LLP
  • Article

    Québec Bill 112: Significant Changes To Duties On Transfers Of Immovables

    The Québec 2016-2017 Budget tabled by Finance Minister Carlos Leitão on March 17, 2016, announced significant changes to the Act respecting duties on transfers of immovable...
    CanadaReal Estate and Construction
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    $1.7M For CRA's "Malicious Prosecution" Set Aside On Appeal

    The next step in this saga for the Samaroos would be to seek leave of this decision to the Supreme Court of Canada.
    CanadaTax
    KPK Law LLP
    KPK Law LLP
  • Article

    Action In Damages Against Revenu Québec: Recent Developments

    The recent judgment Naples Pizza (1981) inc. c. Agence du revenu du Québec, 2019 QCCS 710 delivers some developments of interest, particularly with respect to prescription and the extra-contractual
    CanadaTax
    Spiegel Sohmer
    Spiegel Sohmer
  • Article

    Investing In Canadian Private Corporations Through RRSP, RRIF, And TFSA

    There are many eligible investments, such as shares of Canadian private corporations, that can be held in a Registered Retirement Savings Plan (RRSP) or a Tax-Free Savings Account (TFSA)
    CanadaTax
    Crowe
    Crowe
  • Article

    IRS Offers Second Chance To Disclose Hidden Offshore Accounts

    The IRS has announced a new amnesty program for U.S. persons with undisclosed foreign accounts or entities. U.S. persons with foreign accounts are required to report the existence of the accounts annually on Form TD F 90-22.1.
    CanadaTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    Loss Consolidation Under GAAR: When Interpretation And Judgement Decide The Outcome

    Quebecor v. HMK shows how a well-framed economic narrative can support a CRA loss consolidation challenge...
    CanadaTax
    Counter Tax Litigators LLP
    Counter Tax Litigators LLP
  • Article

    New Québec Tax Obligations As Of January 1st, 2020

    Such DAP may also have the obligation to register for QST purposes, including under the non-resident supplier regime
    CanadaTax
    McCarthy Tétrault
    McCarthy Tétrault
  • Article

    Proposed Simplification to U.S. Rules Regarding Tax-Free International Reorganizations

    A change in how tax-free "statutory" mergers can take place.
    CanadaTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    Revised Income Splitting Proposals

    On July 18, 2017, the Department of Finance released a series of controversial tax proposals aimed at closing perceived tax "loopholes" that involve the taxation of private corporations and their shareholders.
    CanadaTax
    Fogler, Rubinoff LLP
    Fogler, Rubinoff LLP
  • Article

    Signed A Leaseback Agreement For Your New Condo? Congratulations! According To The CRA You Are Now A Builder!

    If you are or your client is one of the many thousands of people who have purchased a new condo unit for the purpose of renting it out and if you or they have signed a leaseback agreement with a builder or another company, you should be aware of the potential pitfalls.
    CanadaTax
    Barrett Tax Law
    Barrett Tax Law
  • Article

    Unwinnable From The Start: A Deemed-Resident Trust's Appeal, Chobham Corporation Ltd. v. HMK

    A Panama-based trust with a Quebec contributor faced federal surtax and denied provincial abatement despite paying Quebec tax, creating a situation where it was taxed as residing nowhere in Canada. The Tax Court dismissed the appeal, calling the outcome unfair but mechanically required by statute, illustrating how some tax disputes are predetermined by clear statutory language regardless of perceived unfairness.
    CanadaTax
    Counter Tax Litigators LLP
    Counter Tax Litigators LLP
  • Article

    U.S. Supreme Court Declines To Hear Case Deciding That The Internal Revenue Service ("IRS") Can Require Disclosure Of Tax Accrual Work Papers

    The U.S. Supreme Court rendered this week a highly anticipated decision that affects tax practitioners and their corporate clients. It declined to review a decision of the First Circuit Court of Appeals in Textron v. United States.
    CanadaTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    CRA's New Tax Policy On Business Aviation: One Year Later

    The Canada Revenue Agency's (CRA) previous position on taxable benefits associated with the personal use of business aircraft was cancelled in 2012.
    CanadaTransport
    Spiegel Sohmer
    Spiegel Sohmer
  • Article

    Alberta Budget 2017

    The province has seen two consecutive years of recessions as a result of the low price of oil.
    CanadaEnergy and Natural Resources
    Borden Ladner Gervais LLP
    Borden Ladner Gervais LLP
  • Article

    New Tax Credit For Investments In Clean Hydrogen Production

    The federal government announced a refundable tax credit for investments in clean hydrogen production in Tuesday's budget.
    CanadaEnergy and Natural Resources
    MLT Aikins LLP
    MLT Aikins LLP
  • Showing 721–740 of 3220 results

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