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  • Article

    CRA Tax Rulings Allow Multiplication of Small Business Deduction For Professional Partnerships

    In light of the recent amendments to the Business Corporations Act (Ontario) and the Regulated Health Professions Act (Ontario) permitting doctors and dentists to split income with family members through professional corporations, Ontario doctors and dentists will want to take note of two rulings (2004-0104681R3 and 2005-0130131R3) recently released by the Canada Revenue Agency ("CRA").
    CanadaTax
    Gowling WLG
    Gowling WLG
  • Article

    Dissolved Corporation Lacks Standing In Tax Court

    In 1455257 Ontario Inc., the Federal Court of Appeal overruled its prior precedent and held that a dissolved corporation lacked capacity to initiate a Tax Court of Canada appeal.
    CanadaTax
    Gowling WLG
Gowling WLG
  • Article

    Sell Now! (How The 2016 Budget Will Impact Business Owners' Exit Strategies)

    Back in 2014 I wrote an article reviewing the significant impact on business owners of potential changes to the taxation of Eligible Capital Property that had been floated in the 2014 Federal Budget.
    CanadaTax
    Minden Gross LLP
    Minden Gross LLP
  • Article

    Sell Now! - How The 2016 Budget Will Impact Business Owners' Exit Strategies

    Back in 2014 I wrote an article reviewing the significant impact on business owners of potential changes to the taxation of Eligible Capital Property that had been floated in the 2014 Federal Budget.
    CanadaTax
    Minden Gross LLP
    Minden Gross LLP
  • Article

    Director's And Officer's Tax Liability When Serving On Boards—and Resigning To Prevent Corporate Tax Liability

    A director of a corporation may be held personally liable when the corporation fails to deduct, withhold, remit, or pay certain taxes.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Directors Beware: CRA Can Come After You For Unpaid Source Deductions

    A corporation, for both general and tax purposes, is recognized as a separate legal entity from its shareholders, unlike a partnership or a sole proprietorship.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Federal Court Of Appeal Overturns GAAR Assessment On The Existence Of Alternative Transactions, Leading To No Violation Tax Abuse Or Tax Avoidance Of GAAR: 3295940 Canada Inc. v The King

    In 3295940 Canada Inc. v The King, A-201-22, the Federal Court of Appeal (the "FCA") overturned the CRA's GAAR abuse analysis on the basis that similar economic result can be reached by alternative transactions.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    New Income Trust Conversion Rules

    On July 14, 2008, the Minister of Finance released proposed amendments to the Income Tax Act (Canada) (the ITA) which are intended to permit the conversion of income trusts into corporations (the Proposals).
    CanadaTax
    Bennett Jones LLP
    Bennett Jones LLP
  • Article

    Tax Court of Canada Rules U.S. Limited Liability Company is Treaty Resident

    On April 8, 2010, the Tax Court of Canada held that a U.S. limited liability company (LLC) was "liable to tax" in, and therefore a resident of, the United States for purposes of the "Canada-United States Income Tax Convention" (the Treaty).
    CanadaTax
    Osler, Hoskin & Harcourt LLP
    Osler, Hoskin & Harcourt LLP
  • Article

    United States Permanent Establishment Enforcement And Expansion

    Recently, U.S. Internal Revenue Service (IRS) and Department of Treasury officials made statements expressing the increasing focus of U.S. enforcement activity and audit scrutiny on permanent establishment issues.
    CanadaTax
    Osler, Hoskin & Harcourt LLP
    Osler, Hoskin & Harcourt LLP
  • Article

    Beware The Pac-Man Rule—Or Not

    Among the landmarks of 1980s popular culture was a wildly successful arcade game: Pac-Man. The goal?
    CanadaCorporate/Commercial Law
    Torys
    Torys
  • Article

    Powering The Cloud: How Alberta Is Reshaping Its Electricity System For Data Centres

    On December 11, 2025, Alberta enacted a coordinated set of legislative measures to respond to the rapid growth of large-scale data centres and their impact on the provincial electricity system.
    CanadaEnergy and Natural Resources
    Gowling WLG
    Gowling WLG
  • Article

    Canadian Budget 2017

    On March 22, 2017 ("Budget Day"), the Honourable William Francis Morneau, Canada's Minister of Finance, tabled Canada's annual federal budget ("Budget 2017").
    CanadaGovernment, Public Sector
    Aird & Berlis LLP
    Aird & Berlis LLP
  • Article

    Solicitor-Client Privilege and Tax Advice – Recent Cases

    Several recent Canadian cases have dealt with the issue of whether documents and other information and communications involving tax advisers are privileged. This article surveys some of these recent cases.
    CanadaGovernment, Public Sector
    Borden Ladner Gervais LLP
    Borden Ladner Gervais LLP
  • Article

    The GIFI – Extra Compliance Burden for Canadian Corporate Taxpayers

    CanadaLitigation, Mediation & Arbitration
    PwC Management Services LP
    PwC Management Services LP
  • Article

    OPSTC And OCASE Tax Credit Rates To Be Grandfathered

    The 2015 Ontario Budget introduced changes to reduce the OPSTC and OCASE tax credit rates for expenditures incurred after April 23, 2015.
    CanadaMedia, Telecoms, IT, Entertainment
    Goodmans LLP
    Goodmans LLP
  • Article

    2016 Federal Budget: Key Tax Changes

    The 2016 Federal Budget was released March 22nd. The overarching theme is to provide increased benefits and relief to middle-class individuals and to close or restrict cross-border tax planning.
    CanadaTax
    Lawson Lundell LLP
    Lawson Lundell LLP
  • Article

    Anti-Discrimination And The Canada-UK Tax Treaty

    Saipem UK Limited v. the Queen is the first Canadian case wherein the Tax Court of Canada has decided with respect to the anti-discrimination provisions contained in a Canadian tax convention, being Article 22 of the Convention Between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland (Treaty).
    CanadaTax
    McCarthy Tétrault
    McCarthy Tétrault
  • Article

    Budget 2018: Developments Affecting Private Companies

    Budget 2018 contains two new measures to deter the accumulation of passive assets within private corporations. These changes are a welcome departure from the Federal Government's July 18, 2017 ...
    CanadaTax
    Miller Thomson
    Miller Thomson
  • Article

    Changes To Tax Treatment Of Income Trusts And Publicly-Traded Partnerships

    On October 31, 2006, the Minister of Finance announced a sweeping reform of the tax treatment of income trusts and publicly-traded partnerships.
    CanadaTax
    Stikeman Elliott LLP
    Stikeman Elliott LLP
  • Showing 941–960 of 1610 results

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