The Canadian federal government has been concerned for some time about "treaty shopping" by non-residents.
In order to be a "co-operative corporation" for the purposes of the ITA, the corporation must satisfy the requirements set out in section 136(2)(a) of the ITA.
Collins Barrow National Cooperative Inc.
The 2014 Federal Budget introduced legislation to eliminate the graduated rate of taxation for testamentary trusts.
Over the past six years, the United States has become increasingly concerned that Americans are stashing money offshore, essentially evading U.S. tax.
In Gariepy v. the Queen, the Tax Court considered whether two directors had effectively resigned from their positions.
Lately I’ve noticed a number of articles regarding bank accounts held offshore by Canadian residents.
Justice Patrick Boyle recused himself from the two remaining issues with which he was seized in the transfer pricing case – costs and the content of the court’s public file.
An appeal was filed with the Federal Court of Canada in Vancouver seeking a declaration that the enforcementof the US FATCA on Canadian soil is unconstitutional.
In Achim Bekesinski and Her Majesty the Queen, the taxpayer, as director of a corporation, was personally reassessed by the Minister of National Revenue.
Blaney McMurtry LLP
Two recent court decisions provide a vivid reminder that timing obligations are not the taxpayer's alone. The CRA has them, too.
Blake, Cassels & Graydon LLP
On August 29, 2014, the Minister of Finance released for consultation draft legislative proposals to amend the Income Tax Act (Canada).
Minden Gross LLP
Is it time to sell your winning stocks? Given recent stock market highs, plenty of investors are thinking that now’s the time to sell and lock in those juicy gains.
Minden Gross LLP
Back-to-school shopping is a time-honoured tradition, and the bill for pencils, notebooks and a new outfit for the classroom usually seemed manageable.
The transfer pricing adjustment rules apply when transactions undertaken by non-arm’s length parties do not reflect arm’s length terms and conditions.
We have previously blogged about litigation apps and the absence of Canadian litigation and tax litigation apps.
Frequently we have clients who want to move their existing business venture from one company to another.
Crowe Soberman LLP
Did you know that the U.S. Department of Homeland Security is now tracking your entrance to and exit from the U.S. by land, sea, and air?
In my previous blog post on this subject, I discussed the list of required information in order to substantiate an Input Tax Credit (ITC) claim.
Stikeman Elliott LLP
On August 11, a constitutional challenge to the new FATCA provisions contained in Part XVIII of the Income Tax Act (Canada) was filed in Federal Court in Vancouver.
Earlier this year, McKesson Canada Corporation appealed the decision of the Tax Court of Canada in McKesson Canada Corporation v. The Queen.