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In its 2017 Federal Budget release, the Federal Government noted a continued concern with tax planning strategies involving private corporations.

IRS Notice 2014-52 includes broad new rules designed to increase the tax cost of U.S. corporate inversions and reduce opportunities to lower global effective tax rates.

Mac's, an Ontario corporation, was a wholly-owned subsidiary of Couche-Tard Inc. ("CTI"). In April 2005, Mac's borrowed $185 million from Sidel Corporation, a related Delaware corporation.

Canada's new Productivity Mega Deduction allows businesses to immediately write off the full cost of newly-acquired capital assets rather than deducting gradually over years, marking a permanent shift in the country's business tax system. How will this measure impact capital-intensive industries and position Canada's tax competitiveness against the United States and OECD nations?

On March 22, 2017, Finance Minister Bill Morneau tabled the 2017 Federal Budget.

Section 212.1 is a provision that is intended to prevent a non-resident (the transferor) from stripping surplus out of a Canadian resident corporation (Canco) as a capital gain which might be...

On July 18, 2017, Canada's Minister of Finance released a consultation paper and draft legislative proposals that target the use of private corporations to sprinkle income among family members, hold passive investments and strip surplus by converting corporate surplus into capital gains.

The Federal alternative minimum tax (“AMT”) regime is intended to ensure that individuals, including certain trusts, pay a certain minimum level of tax where income tax calculated under the regular rules is reduced...

The media frenzy and uproar over the July 18, 2017 tax proposals that had been routine throughout the summer and early fall has quieted down significantly ever since Minister Morneau's "Santa Claus" ...

That day, and most of my summer since, have been anything but a vacation.

Those of you who happen to own shares in a private corporation, especially a family owned business should be aware of a couple common tax traps to avoid.

Spinoffs or splitoffs are commonly sought by shareholder activists of public companies to increase shareholder value.

A tax opinion may confirm that a filing position is defensible, but does it address how that structure will perform when the Canada Revenue Agency challenges it? This analysis examines the gap between implementation support and dispute readiness, exploring what remains unanswered after the opinion is delivered and why multiple participants may assess different aspects without evaluating the structure outside the implementation frame.

Many Canadian tech entrepreneurs would like to benefit from certain advantages of being a U.S.-based company. At the same time, there are considerable tax and funding incentives offered to startups operating in Canada.

For many US companies Canada can seem like another home market, with its largely similar culture, language and business environment. However, it's important to pay attention...

Though both may end up paying a similar tax rate on the income generated by their investments, the CCPC would be earning more income due to its higher starting capital.

On January 17, 2014, the Canada Revenue Agency finally announced its intention to introduce a registration system for tax preparers who prepare tax returns for a fee.