BLG is a leading, national, full-service Canadian law firm focusing on business law, commercial litigation, and intellectual property solutions for our clients. BLG is one of the country’s largest law firms with more than 750 lawyers, intellectual property agents and other professionals in five cities across Canada.
The application for leave to appeal the Federal Court of Appeal’s decision in Prescient Foundation v Minister of National Revenue was dismissed by the Supreme Court of Canada ("SCC") with costs on November 28, 2013.
The application for leave to appeal the Federal Court of
Appeal's decision in Prescient Foundation v Minister of
National Revenue was dismissed by the Supreme Court of Canada
("SCC") with costs on November 28, 2013. Unfortunately,
those waiting to see if the SCC would rule on whether gifting to a
foreign non-qualified donee is permitted under the
non-discrimination clause in Article XXI of the Canada-U.S. Tax
Treaty will have to wait for a future case on the issue to
arise.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
