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With increasing frequency, Canadian corporations are venturing across the border into the United States to perform services or sell their products.

The federal budget tabled on March 22, 2011 (the 2011 Budget) contains a number of proposed amendments to Canada’s Income Tax Act (Tax Act).

On April 23, 2014, the Federal Court of Appeal released its decision in "The Queen v Lehigh Cement Limited".

Important changes to the taxation of registered retirement savings plans and registered retirement income funds (collectively referred to as an "RRSP", although the changes apply equally to both types of plans) were enacted late last year that significantly reduce the types of investments that can be held in an RRSP without being subject to onerous taxes.

Damages, settlement payments and indemnity payments frequently arise as a result of disputes in the commercial context. The income tax treatment of such payments can significantly impact their financial...

In a prior blog post, I said that solicitor client privilege remains strong in Canada.

The Federal Court of Appeal upheld the lower court’s interpretation and application of the inter-corporate dividend deduction under subsection 112(1) of the Income Tax Act.

The business and legal landscape in Québec continues to evolve – and offers growing opportunities for foreign-based companies doing business in Canada’s second-largest province. In this update, we outline recent key developments in financial services reform, litigation, tax incentives and other areas.

In HLP Solution Inc. v. The Queen (2015 TCC 41 ) the Tax Court held that a CRA employee lacked the necessary impartiality to testify as an expert witness because of her prior involvement in auditing the taxpayer.

The Canada Revenue Agency (the "CRA") recently issued Tax Ruling #2007- 0224741R3 "Capital of a Municipal Corporation".

Scientific research and experimental development ("SR&ED") claims can present some of the most complex and challenging tax disputes, requiring a practical and pragmatic approach.

From the moment of its enactment on December 22, 2017, the U.S. tax reform legislation commonly referred to as the "Tax Cuts and Jobs Act" (the "TCJA") signalled a seismic shift in U.S. tax policy.

Taxpayers who previously engaged in non-CCPC tax planning have a decision to make – and ideally soon.

In our previous article, we examined proposed amendments that would allow the Canada Revenue Agency (the "CRA") to compel sworn testimony during an audit...

In Goldhar v The King, the CRA reassessed Mr. David Goldhar's 2008 to 2011 tax returns beyond the normal reassessment period by including unreported shareholder benefits and imposing gross negligence and foreign reporting penalties.

The February 26, 2008 Canadian federal budget did not contain much in the way of significant tax changes.

the Federal Court of Appeal upheld a decision by Justice Hershfield of the Tax Court of Canada, finding for the respondent, the National Life Assurance Company of Canada.