Mondaq Canada: Tax
McInnes Cooper
The Canadian federal government has been concerned for some time about "treaty shopping" by non-residents.
Lerners
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.
MNP
Over the past six years, the United States has become increasingly concerned that Americans are stashing money offshore, essentially evading U.S. tax.
Dentons (Canada)
In Gariepy v. the Queen, the Tax Court considered whether two directors had effectively resigned from their positions.
MNP
Lately I’ve noticed a number of articles regarding bank accounts held offshore by Canadian residents.
Dentons (Canada)
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.
TaxChambers LLP
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.
TaxChambers LLP
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.
MNP
The transfer pricing adjustment rules apply when transactions undertaken by non-arm’s length parties do not reflect arm’s length terms and conditions.
Dentons (Canada)
We have previously blogged about litigation apps and the absence of Canadian litigation and tax litigation apps.
MNP
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?
MNP
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.
Dentons (Canada)
Earlier this year, McKesson Canada Corporation appealed the decision of the Tax Court of Canada in McKesson Canada Corporation v. The Queen.
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Moodys Gartner Tax Law LLP
Why would a country with a seven to ten year wait list to acquire citizenship have so many citizens headed for the exit?
Minden Gross LLP
We all know the cardinal rule relating to RRSP withdrawals before maturity: DON’T DO IT!
Moodys Gartner Tax Law LLP
Virtually all Canadian snowbirds know they must keep track of how many days they are in the US and outside of Canada because "bad" tax and non-tax surprises await those who are in or out of either country too long.
Moodys Gartner Tax Law LLP
In 280 BC the Greek King Pyrrhus won a decisive battle against the Roman army. However in winning the battle, Pyrrhus’s army suffered great losses and when Rome had a chance to reconnoiter, it easily defeated what remained of the Greek’s army.
Davies Ward Phillips & Vineberg
Form W-8BEN-E is a critical component of foreign entity compliance with the Foreign Account Taxpayer Compliance Act.
Moodys Gartner Tax Law LLP
One thing is for sure… Canadians continue to invest significant amounts of money in the US.
Collins Barrow National Cooperative Inc.
Provinces have legislation that allows for the creation of not-for-profit entities to collect fees from owners of certain real property.
Collins Barrow National Cooperative Inc.
A life interest in real estate provides an exclusive right to use a property during the lifetime of the holder of the interest.
MNP
The transfer pricing adjustment rules apply when transactions undertaken by non-arm’s length parties do not reflect arm’s length terms and conditions.
McMillan LLP
Budget 2014 proposes a number of changes to the taxation of trusts and estates under the Income Tax Act (Canada) (the "Tax Act") that will have a significant impact on tax planning.
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