Mondaq Canada: Tax
Minden Gross LLP
Part 1 of this Series reviewed what the 21-year deemed disposition rules are and introduced three approaches to planning that appear to be most commonly used to manage the effects of the 21-year...
TaxChambers LLP
IRC section 267A, added December 2017, denies a deduction to a US-situated payer of interest or a royalty to a related non-US hybrid party or as part of a hybrid transaction.
Fasken
On June 21, 2018, the Ontario Court of Appeal handed down a decision in the case of Canada Life Insurance Company of Canada v. the Attorney General of Canada and Her Majesty the Queen
Rotfleisch & Samulovitch P.C.
Ordinarily the Tax Court of Canada is proper jurisdiction for challenging assessments issued under the Canadian Income Tax Act.
Rotfleisch & Samulovitch P.C.
Over his career, the entrepreneur started several businesses some of which failed and some of which succeeded.
Rotfleisch & Samulovitch P.C.
Trust has two beneficiaries, C and D, each equally entitled to Trust's capital.
McCarthy Tétrault LLP
For decades the City of Toronto has offered reduced municipal tax rates to charities and heritage properties, and this year, a new sub-class was created to support not-for-profit arts...
Rotfleisch & Samulovitch P.C.
Canada taxes its residents on their worldwide income; it taxes non-residents on their Canadian-sourced income. Many countries tax income in the same way.
Rotfleisch & Samulovitch P.C.
When non-Canadian residents decide to start a corporation in Canada to operate a business, an important typical question is how to fund that business.
Rotfleisch & Samulovitch P.C.
When a Canadian taxpayer is facing a tax audit from the CRA, the conduct and methodology of the tax auditor are subject to a "reasonable minimum standard".
Borden Ladner Gervais LLP
Les autorités fiscales détiennent plusieurs pouvoirs afin de s'assurer de la véracité et du bien-fondé des représentations du contribuable.
McCarthy Tétrault LLP
In its South Dakota v. Wayfair decision published on June 21, 2018, the Supreme Court of the United States overturned the position that had been prevailing for half a century
Osler, Hoskin & Harcourt LLP
On June 27, 2018, the Department of Finance released new GST/HST rules for carbon emission allowances (the New Rules).
TaxChambers LLP
The ruling reflects that deemed trust rules are "quite strict," and should be a warning to lenders to investigate a borrower's existing tax obligations, Toronto sales tax specialist Simon Thang said June 12.
Fasken
The MLI has been signed by 78 countries including Canada.
TaxChambers LLP
The Crown, on behalf of the CRA, sued TD Bank to recover money that it received from one of its customers.
Crowe Soberman LLP
The entire entertainment and media market in Canada was valued at 54.6 billion Canadian dollars in 2015, 56 billion a year later, and is predicted to grow by another eight billion by the end of 2020.
Wildeboer Dellelce LLP
On June 7, 2018, Ontario made an "about-face" and elected a majority Progressive Conservative (PC) government under PC Leader and premier-elect Doug Ford for the first time in 15 years.
Minden Gross LLP
This paper will focus on the rules in the Income Tax Act (Canada) relating to taxable preferred shares ("TPS") and short-term preferred shares ("STPS") as they might apply in the private corporation context.
TaxChambers LLP
Financial services are generally an exempt supply for which no GST/HST would be charged.
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Rotfleisch & Samulovitch P.C.
At bottom, the bitcoin system is a system of digital currency. In particular, a bitcoin functions as a digital asset, serving as a medium of exchange.
Rotfleisch & Samulovitch P.C.
Cryptocurrencies such as Bitcoin, Dash, Ether, Litecoin, Ethereum and Ripple have been the subject of intense media coverage in recent months due to their general astronomical surge in value.
Collins Barrow National Incorporated
In recent years, digital currencies called "cryptocurrencies" have exploded in mainstream popularity.
Crowe Soberman LLP
Vendors doing business in Canada and who are located outside of Ontario are usually required to register for GST/HST purposes and collect the appropriate tax, whether it is the Goods and Services Tax (GST) or the Harmonized Sales Tax (HST).
Collins Barrow National Incorporated
From an investment perspective, mutual funds and exchange-traded funds (ETFs) make sense for many Canadians. They allow them to reduce investment risk by diversifying their holdings through exposure to...
Dentons
On Thursday, June 7, 2018, the 2018 Ontario Election saw an approximate 58 percent voter turnout—the highest since 1999—resulting in a majority government for the Ontario Progressive Conservative Party...
TaxChambers LLP
The ruling reflects that deemed trust rules are "quite strict," and should be a warning to lenders to investigate a borrower's existing tax obligations, Toronto sales tax specialist Simon Thang said June 12.
TaxChambers LLP
The Crown, on behalf of the CRA, sued TD Bank to recover money that it received from one of its customers.
Blaney McMurtry LLP
Following are the summaries of this week's civil decisions of the Court of Appeal for Ontario.
O'Sullivan Estate Lawyers LLP
Concerns about inheritance of the cottage or vacation property, including who, how and when are often worrisome for owners. In our last article, we discussed personal and emotional considerations in planning for the succession of a cottage (or other vacation home).
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