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  • Article

    Foreign Reporting Penalties: Similarities, Differences, And Interplay

    The CRA is imposing more penalties, including foreign reporting penalties. These penalties might, prima facie, look the same, but there are key differences.
    CanadaTax
    Counter Tax Litigators LLP
    Counter Tax Litigators LLP
  • Article

    Further Significant Increases To The CRA's Prescribed Interest Rates

    The Canada Revenue Agency ("CRA") increased its prescribed rates of interest for the third quarter by 60% over Q3 2022 levels after inflation reached heights not seen in decades.
    CanadaTax
    MLT Aikins LLP
    MLT Aikins LLP
Article

Highlights Of Canadian Federal 2019 Budget

On March 19, 2019, the Department of Finance (Canada) tabled a budget (the "Budget") in anticipation of its upcoming fall election. Given the substantial tax changes proposed (and enacted)
CanadaTax
Torkin Manes LLP
Torkin Manes LLP
  • Article

    How Trump's Tax Returns Can Be Legally Released

    United States President Donald Trump has given every excuse not to release his tax returns—first, he was under audit, then, it was that the American people just do not care about his tax returns...
    CanadaTax
    Devry Smith Frank LLP
    Devry Smith Frank LLP
  • Article

    Investir dans sa conformité fiscale afin d'éviter le litige

    Le contexte socio-économique actuel au Québec a évidemment comme effet d'affaiblir les contribuables. Les coûts augmentent dans pratiquement toutes les domaines...
    CanadaTax
    Miller Thomson
    Miller Thomson
  • Article

    IRS Announces Expanded "No-Rule" Area For Spinoffs

    On January 27, 2015, Yahoo Inc. announced its intention to seek an IRS private ruling that would confirm its view that the inclusion of a relatively small active business along with its stake in Alibaba Group Holding Ltd. would meet the "active business requirement" for a tax-deferred spinoff under the Internal Revenue Code.
    CanadaTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    IRS Takes Steps To Fulfill Flaherty’s Promise Of Relief For Canadian Residents Who Have Not Filed US Tax Returns

    On January 9, 2012 the Internal Revenue Service ("IRS") issued a statement that contains two very important announcements for Canadian residents who have US tax and filing obligations:
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    IRS Tax Scam – Fake Form W-8BEN

    Form W-8BEN (for individuals) and W-8BEN-E (for business entities) is the "Certificate of Foreign Status of Beneficial Owner for United States Tax Withholding."
    CanadaTax
    Fuller Landau
    Fuller Landau
  • Article

    Legal Advisers' Files Are Not Archives For Tax Authorities, SCC Rules

    The Supreme Court of Canada released two decisions last week regarding the power of the Canada Revenue Agency to demand production of information and documents, including accounting records...
    CanadaTax
    Blake, Cassels & Graydon LLP
    Blake, Cassels & Graydon LLP
  • Article

    Legal Trends 2016: Tax

    Elected in October 2015, Canada's new Liberal government has proposed a tax platform featuring significant changes, including a four per cent increase (to 33 per cent) in the federal tax rate for individuals on income over C$200,000 and a 1.5 per cent drop in the middle-income tax rate.
    CanadaTax
    Blake, Cassels & Graydon LLP
    Blake, Cassels & Graydon LLP
  • Article

    Mandatory Disclosure Of Uncertain Tax Treatments Coming Into Effect

    On February 4, 2022, the Department of Finance (Finance) released draft legislation that, among other things, implemented the 2021 Budget's commitment to expand Canada's mandatory tax disclosure requirements.
    CanadaTax
    Cassels
    Cassels
  • Article

    McKesson: Appellant’s Factum Filed

    In McKesson, the Tax Court upheld the CRA's transfer price adjustments (made pursuant to section 247 of the Income Tax Act (Canada).
    CanadaTax
    Dentons Canada LLP
    Dentons Canada LLP
  • Article

    Navigating The Federal Flipped Property Rule: What You Need To Know

    With real estate audits on the rise, staying ahead of tax rules has never been more crucial. The Canada Revenue Agency (the "CRA'') and Revenu Québec have intensified their scrutiny of real estate transactions.
    CanadaTax
    Miller Thomson
    Miller Thomson
  • Article

    New Rules Replace The GILTI — Applicable 2026

    President Trump's Tax Cuts and Jobs Act in 2017 was the largest tax reform in the United States since 1986. Part of this reform were new rules applicable to controlled foreign corporations (CFC) earning so-called "global intangible low tax income" or "GILTI".
    CanadaTax
    Altro LLP
    Altro LLP
  • Article

    Objections & Appeals Of CRA Assessments

    After COVID, the CRA seems to be really ramping up its audit activities, both for GST/HST and income tax matters. Once a Notice of Assessment is issued, reversing the CRA's position...
    CanadaTax
    Millar Kreklewetz
    Millar Kreklewetz
  • Article

    Ontario Production Services Tax Credit

    Tax credits are crucial to the film and television industry, and Ontario has been a particularly attractive location for productions since the beginning of its film and television tax credit program.
    CanadaTax
    KPK Law LLP
    KPK Law LLP
  • Article

    PayPal CRA Court Order - When Shared Economy Becomes Underground Economy

    A tax fishing expedition is where CRA goes to a third party to obtain general third party information that may aid them in auditing taxpayers rather than the subject of the information order.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Providing Crossborder Inter-Company Goods Or Services? Don't Forget About Transfer Pricing!

    In the transportation and logistics industry, as with other industries, it is common for corporations in the same multinational group to provide goods and services to one another. If the parties to such a transaction...
    CanadaTax
    Miller Thomson
    Miller Thomson
  • Article

    Québec Sales Tax (QST) On Insurance Premiums: Increase From 9% To 9.975% Effective January 2027

    The Québec government enacted Bill 99 on October 28, 2025 (Chapter 27), confirming an increase in the QST rate applicable to insurance premiums.
    CanadaTax
    Dentons Canada LLP
    Dentons Canada LLP
  • Article

    RRSP Meltdown Strategy: A Canadian Tax Lawyer's Tax Guidance

    The Registered Retirement Savings Plans (RRSP) offer Canadians a great opportunity to defer tax in their retirement savings.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Showing 801–820 of 3220 results

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