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Whether you are transferring patent or acquiring rights in a patent, the tax consequences can vary greatly depending on how the transfer is structured.

On June 11, 2010, the Federal Court of Appeal in "Exida.com Ltd. Liability Co. v. Her Majesty the Queen" (2010 DTC. 6935) resolved two conflicting decisions of the Tax Court of Canada on the issue of whether a non-resident corporation that does not have any tax payable under the "Tax Act" may be subject to a late-filing penalty for failing to file an income tax return within the prescribed time in the "Tax Act".

Many tax rectification cases address situations in which certain transaction documents contain errors that do not accord with the parties’ intent to minimize or avoid taxes.

In July 2013, the Organisation for Economic Co-operation and Development released its Action Plan on Base Erosion and Profit Shifting.

In “Hanmar Motor Corporation v. The Queen”, the Tax Court of Canada upheld the Minister of National Revenue's (the "Minister") decision to disallow the deduction of a settlement payment made under the “Employment Standards Act” of Ontario (the "ESA").

Canada's film and television industry is among the most vibrant in the world, due in part to its generous federal and provincial tax incentives. These include the Canadian Film or Video Production Tax Credit ("CPTC"), a fully refundable tax credit jointly administered by the Canada Revenue Agency ("CRA") and the Canadian Audio-Visual Certification Office ("CAVCO").

The Federal Court of Appeal released its decision in The Queen v. Prevost Car Inc. on February 26, 2009. The CRA’s appeal was denied. The case turned on the meaning of the term “beneficial owner.”

The Tax Court of Canada has found that an international businessman who hired lawyers and accountants to organize his financial affairs was not liable for tax penalties assessed against him.

Many people in agriculture don’t understand that taxes are a sign of prosperity.

If there's one message manufacturers can take away from the most recent federal budget, it's this: the future is now.

On November 7, 2006, Canada’s Parliament passed a motion approving the Minister of Finance’s proposals to introduce an entity-level tax on distributions from income trusts and certain publicly-listed Canadian partnerships. The proposed rules, which were announced on October 31, 2006, are intended to eliminate the tax imbalance created by income trusts and aim to tax such entities in the same general manner as corporations. In doing so, the government sought to stem the tide of corpor

Business owners often overlook the tax implications of unanimous shareholder agreement provisions, which can trigger unintended changes in corporate control, loss of Canadian Controlled Private Corporation status, and deemed year-ends with significant consequences. Understanding how provisions affect de jure and de facto control, share option rights, and acquisition of control rules is essential before finalizing these powerful governance documents.

The U.S. recently enacted the One Big Beautiful Bill (OBBB), a major tax reform affecting individuals and corporations. While primarily U.S.-focused, the legislation has important consequences for Canadians with U.S. income, investments, or business operations.

In the March 2013 Federal Budget, the Department of Finance indicated that it intended to initiate a consultation process on certain "treaty shopping" practices.

Business owners are often tempted to dip into the corporation's pockets to pay for personal expenses. A temptation which seems like a relatively insignificant transgression but in reality, is a decision that can create dire tax consequences.

On June 29, 2006, the federal Department of Finance released draft amendments to the Income Tax Act (Canada) (the Act) aimed at implementing the government’s 2006 budget proposal to lower the income tax rate on dividends paid by large corporations. Interested parties are invited to submit comments on the proposal by September 15, 2006. It is expected that legislation effective for eligible dividends paid after 2005 will be introduced this fall.

If you are an employee, your tax-filing deadline for 2015 returns is May 2. If you haven't filed yet, better get on with it!

Calgary is a growing and dynamic city that presents tremendous opportunity for businesses looking to expand. Historically known as an entrepreneurial oil and gas city, Calgary has embarked on a robust journey of economic diversification and is perfectly positioned for economic growth