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Article
Submission Made To The Alberta Government Proposing Amendments To The Judicature Act To Improve The Ability To Correct Bona Fide Mistakes
The Supreme Court of Canada's 2016 and 2022 decisions in the Fairmont Hotels and Collins Family Trust cases respectively have substantially reduced the availability to residents of...
CanadaTax
Moodys Private Client Law
Article
Summary Of Comments On Canadian FATCA legislation
Canada and the U.S. executed a model 1 intergovernmental agreement which relieved Canadian financial institutions from many onerous obligations under FATCA.
CanadaTax
Moodys Private Client Law

Supreme Court Endorses Key Tax Principle: Tax Law Should Follow Private Law Agreements

The Supreme Court of Canada recently endorsed a fundamental principle in Canadian tax law – namely that absent sham or statutory recharacterization rules, "tax law applies to transactions governed by, and the nature and legal consequences of which are determined by reference to, the common law or the civil law" (Québec (Agence du Revenu) v Services Environnementaux AES inc., 2013 SCC 65 at para 45).

Bennett Jones LLP

Supreme Court Of Canada Declines To Hear The Cameco Landmark Transfer Pricing Case

On February 18, 2021, the Supreme Court of Canada announced that it will not hear the transfer pricing tax appeal involving the Government of Canada and Cameco Corporation.

Bennett Jones LLP

Supreme Court Of Canada Renders Decision On Trust Residency

This case involved a reorganization of the capital of a private Canadian operating corporation, the shares of which were indirectly held by Canadian individuals through two Canadian holding corporations.

Stikeman Elliott LLP

Supreme Court Of Canada To Hear Tax Rectification Case

On November 19, 2015, the Supreme Court of Canada granted leave to appeal in Canada (A.G.) v. Groupe Jean Coutu (PJC) inc., 2015 QCCA 838, which addresses the question of when rectification will be granted in the tax context.

Bennett Jones LLP

Tax Court Introduces Common Books Of Authorities Project

Tax Court has implemented a new common books of authorities program for its Toronto courtrooms that will eliminate the need for taxpayers to print copies of certain frequently-cited authorities.

Dentons Canada LLP

Tax Evasion Failure To File Tax Returns Conviction

Erhard Unger was convicted in Penticton, BC of failing to file income tax returns and was fined $1,000.

Rotfleisch & Samulovitch P.C.

Tax Letters: U.S. And Cross-Border Tax Update 2016

Here are some U.S. and cross-border tax items to keep in mind

Tax Memo: August 14, 2012 - Legislative Proposals Released As Consultation Draft

On August 14, 2012, the Department of Finance released for consultation draft legislative proposals that implement measures included in the March 29, 2012 federal budget. Comments on the proposals are due by September 13, 2012.

PwC Management Services LP

Tax Opportunities Under The Indian Act

Although it is not often well-understood in business and tax circles, the Indian Act (the "Act"), coupled with federal and provincial tax laws...

Tax Planning For Indigenous Equity In Canadian Projects

As reported in our prior bulletin, "Four Trends in Indigenous Equity Participation in Canada", we have been monitoring reports of Indigenous equity participation in energy and related infrastructure projects.

Tax Planning For Private Corporations And Their Shareholders - Converting Income Into Capital Gains

On October 19, 2017, the Department of Finance Canada issued a news release advising that it will not move ahead with proposed measures intended to target the conversion of income into capital gains.

Dentons Canada LLP

Tax Planning In A Down Market – Seize The Opportunities

In these difficult times, where asset values may be depressed, there may be some planning opportunities that you can take advantage of in order to free up some cash flow or reduce future taxes payable

Aird & Berlis LLP

Tax Planning Opportunity Closed: Proposed Amendments To The Income Tax Act (Canada) Will Tax Non-Competition Payments

Tax Treatment Of Cryptocurrency Mining

On August 8, 2019, the Canada Revenue Agency (the "CRA") released an Income Tax Ruling, 2018-0776661I7, clarifying its view on the taxation of cryptocurrency miners.

Tax Update: GST/HST Considerations For Canadian Businesses Affected By COVID-19

The Department of Finance and the Prime Minister, Justin Trudeau, announced new support for small businesses on Friday, March 27, 2020.

Blaney McMurtry LLP

The Bowman Moot Problem 2019

The reasons and judgment of the Federal Court of Appeal in Wild v. Canada (Attorney General) (2018 FCA 114) are appealed to the Bowman Supreme Moot Court for Tax Appeals.

Dentons Canada LLP

The Canada Revenue Agency Wants To Know What You Think Of Them

On April 23, 2019, the CRA launched public consultations to find out how it can change and what improvements it can make.

The Employers' Edge - Bill 105, The Supporting Small Businesses Act, Passes Second Reading

Bill 105, or the Supporting Small Businesses Act, recently passed a second reading after debate in the Ontario Legislature.

Showing 941–960 of 9572 results

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