In a recent case the Crown attempted to utilize the GAAR to recharacterize as dividends certain capital gains which had been realized by a family trust and allocated to the minor-aged taxpayers in 2003, 2004 and 2005.
In a recent Tax Court of Canada ruling the Court considered a motion for an Order directing the Appellant to attend and be cross-examined on its List of Documents pursuant to subsection 82(6) and paragraph 88(a) of the Tax Court of Canada Rules.
Last week, a longtime colleague of mine sent me a link to some promotional material that a charitable tax shelter had recently distributed.
Following several months of uncertainty since the announcement of modifications to the Québec mining tax regime, the Québec Minister of Finance and the Economy, Nicolas Marceau, together with the Québec Minister of Natural Resources, Martine Ouellet, have finally announced the amendments that they propose to make to the Mining Tax Act.
The Federal Court of Appeal has determined in Sommerer that subsection 75(2) of the Income Tax Act did not apply to a fair market value sale of property to a trust.
The current immigration bill pending before the US Congress contains provisions that will make it easier for Canadians and retirees to obtain non-immigrant status in the US.
Canada, like many developed countries, restricts the amount of interest a corporation resident in Canada may deduct on loans made by non-residents who are the CRIC’s significant shareholders or their affiliates.
Canada’s 2013 federal budget released on March 21, 2013 introduces a number of measures to strengthen the ability of the Canada Revenue Agency to address international aggressive tax avoidance and to combat international tax evasion so as to maintain and protect Canada’s tax base.
The provincial Minister of Finance has recently released a proposal for a new Québec mining tax regime which would replace the current framework enacted under the Mining Tax Act on June 6, 2011.
A discussion on the attitude towards the tax legislative process.
On May 2, 2013, the Ontario government unveiled its 2013 Budget (the "Budget").
The IRS has recently released statistics on the number of returns it received in 2010 from US citizens with foreign trusts.
The Federal budget which was recently released, proposes to introduce new rules that may have significant tax implications.
During the last provincial elections in Quebec, the Parti Québécois, which now forms the provincial government, promised to change the mining royalties regime to ensure that all mining companies pay financial compensation on the mineral resources they extract.
On January 1, 2011, Canada’s first tax information exchange agreement (TIEA), between Canada and the Netherlands Antilles, entered into force.
On April 29, 2013, the Minister of Finance introduced Bill C-60 to implement certain provisions of the Federal Budget tabled in Parliament on March 21, 2013 (Bill C-60). Bill C-60 follows the Department of Finance's release of a Notice of Ways and Means Motion on April 22, 2013.
Is your company sending people to Canada? If so, you may have a tax exposure you didn’t know about.
Today (May 2, 2013), Ontario Finance Minister, Charles Sousa tabled the province’s 2013 Budget. This year’s budget, titled "A Prosperous and Fair Ontario" is committed to eliminating the deficit by 2017-18 and then reducing the net debt-to-GDP ratio to the pre-recession level of 27%.
In this presentation, Dentons' Doris Bonora and Cheryl Gibson describe the important considerations for business owners regarding estate planning.
A Canada Revenue Agency audit initiative is targeting taxpayers who have recently sold condominium units they did not occupy or occupied for only a short period of time.