1,610 results found

Monday, as part of the Obama administration's announcement of a crackdown on inversions and the release of temporary regulations aimed at tightening the inversion rules...

Operating a business through a corporation can lead to significant deferral advantages over time.

When a taxpayer files a tax return within 3 years of the end of the taxation year, the Canada Revenue Agency ("CRA") is obligated to refund to the taxpayer any overpayments of tax.

At that time, it was clear that the United States was moving toward becoming a friendlier place for entrepreneurs and companies to expand their footprint.

"Help! I'm being audited," are dreaded words uttered by Canadians. They are especially dreaded by business owners because an audit means extra work and extra accounting costs.

The lncome Tax Act (Canada) (the "Act"), contains all manner of "shoals and traps", which may result in unintended tax consequences to the unaware, and in some cases to the aware.

Ontario presents a compelling opportunity for international businesses seeking Canadian expansion, but success hinges on making informed structural and regulatory decisions from the outset. Understanding the nuances between branch offices and subsidiaries, navigating cross-border tax implications, and protecting intellectual property in a new jurisdiction can determine whether your expansion thrives or faces costly complications.

Big plays, bright lights and billion-dollar contracts are all part of the appeal of professional sports, but behind the excitement of the games themselves lie intriguing investment opportunities. Analysts note that investments in sports franchises “consistently outperform traditional asset classes like equity, fixed income and commodities.”

In a rare decision from the bench, the Supreme Court of Canada ("SCC") allowed the appeal of Callidus Capital Corporation in the matter of Callidus Capital Corporation v Her Majesty the Queen.

A holding company is a company that owns shares in another company.

On June 29, 2020, the Government of Alberta unveiled Alberta's Recovery Plan to spur economic recovery following the devastating...

Since investment funds are generally not entitled to claim input tax credits to recover GST/HST that they pay on inputs.

The Department of Finance opened two consultations on a potential patent box regime and on Canada's existing Scientific Research and Experimental Development (SR&ED)...

The Real Estate Services Act and its accompanying regulations (collectively, "RESA") will come into force on January 1, 2022.

On January 17, 2017, I published a blog about the new Alberta Investor Tax Credit program. For those of you who read my original blog, you'll know that I was and remain very critical of the new program.

On February 26, 2009 the Federal Court of Appeal unanimously dismissed the Crown’s appeal in Prévost Car Inc. v. The Queen. The court held that a Dutch holding company was the "beneficial owner" of dividends received from its Canadian subsidiary for purposes of the Canada-Netherlands Income Tax Convention, despite having distributed substantially all of the dividends to its shareholders resident in other countries.

The Federal Court of Appeal upheld a decision of the Tax Court dismissing the taxpayer’s appeal for failure to comply with the rules relating to objections.

As compared to past federal Budgets, Budget 2015 contained fewer (and arguably less controversial) international tax measures.