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1
Tax Treaty Benefits Threatened As Canada Completes Ratification Of OECD's Multilateral Instrument
On August 29, 2019, Canada completed its domestic ratification of the OECD-sponsored Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting
Canada
9 Sep 2019
2
CBSA Publishes Update of Trade Verification Priorities: Are You Ready?
The Canada Border Services Agency (CBSA) updated its online statement of its current trade verification (audit) priorities in July 2019. Importers of goods targeted for verification would be wise
Canada
6 Sep 2019
3
Whistleblowing Pays Off—New CRA Data On First Payments To Informants
The Canada Revenue Agency's (CRA) Offshore Tax Informant Program (OTIP) is a whistleblower program that rewards eligible individuals who come forward to provide CRA with information
Canada
26 Aug 2019
4
Bennett Jones On Tax Disputes - August 2019
The latest edition of Bennett Jones on Tax Disputes, published on Taxnet Pro by Thomson Reuters,...
Canada
19 Aug 2019
5
Bennett Jones Speaks Before Senate Committee On Tax Issues For Energy Investments
On May 29, 2019, Darcy Moch, Greg Johnson and Jared Mackey of Bennett Jones participated on a witness panel before the Standing Senate Committee
Canada
14 Jun 2019
6
New Ratifications Of The OECD's Multilateral Instrument Put Canadian Resource Holding Structures At Risk
Tax-efficient holding structures commonly used by multinational enterprises and private equity firms investing in the Canadian resource sector could soon become subject to anti-treaty shopping measures.
Canada
17 Apr 2019
7
Business Measures In 2019 Federal Budget
The 2019 Canadian federal budget was released on March 19, 2019.
Canada
29 Mar 2019
8
Not Just Linear Property Tax Priorities: Alberta Court Of Appeal On Abuse Of Process And Mootness
In a recent Bennett Jones Update—Property Tax Priorities in Alberta Insolvency Proceedings: Current Uncertainty—we discussed three recent decisions of the Court of Queen's Bench of Alberta
Canada
26 Feb 2019
9
Creditors Cheer SCC Decision On GST Debts
Where a supplier has failed to remit GST to the Crown, ETA subsection 222(3) extends a deemed trust over the unremitted GST in favour of the Crown to cover the supplier's property equal in value to the unremitted GST.
Canada
13 Feb 2019
10
New GST/HST Rules Enacted For Fund Management Fee Arrangements
On December 13, 2018, legislation was passed implementing amendments to the Excise Tax Act (Canada) (the "ETA") first announced in September 2017 ...
Canada
14 Jan 2019
11
Fraud And Knowing Assistance—Between The Innocents
Fraud continues to plague businesses and individuals in Canada and abroad, increasing at an alarming rate. Those involved in asset recovery frequently turn to the equitable doctrine
Canada
11 Jan 2019
12
Orders For Consolidation And Common Hearings Under Tax Court Rule 26
Section 26 of the Tax Court of Canada Rules (General Procedure)1 (the "Tax Court Rules"), referred to as "Rule 26", can be useful where multiple taxpayers are involved in related matters
Canada
9 Jan 2019
13
Ontario And Toronto Land Transfer Tax Update 2018
In the current market of soaring real estate values, particularly in and around the City of Toronto ...
Canada
20 Dec 2018
14
The 2018 Federal Fall Economic Statement—Canada's Response To U.S. Tax Reform
Roughly one year after U.S. tax reform, the Department of Finance has introduced amendments to Canada's income tax laws aimed at encouraging investment in Canada.
Canada
7 Dec 2018
15
No Deemed Trust For Unremitted GST And HST Post-Bankruptcy
In a unanimous decision issued November 8, 2018, the Supreme Court of Canada granted the appeal of the decision of the Federal Court of Appeal in Canada v Callidus Capital Corp, 2017 FCA 162.
Canada
16 Nov 2018
16
Property Tax Priorities In Alberta Insolvency Proceedings: Current Uncertainty
Recent decisions of the Court of Queen's Bench of Alberta have put into question the priority of municipal property taxes in insolvency proceedings.
Canada
16 Nov 2018
17
Bank Loan Repayments May Be Seized Due To Super Priority Of Crown For GST/HST
On May 25, 2018, the Federal Court of Canada released its decision in Her Majesty the Queen v The Toronto-Dominion Bank.
Canada
18 Oct 2018
18
Property Tax Assessments—Why You Should Respond To Requests For Information
The Alberta Municipal Government Act (MGA) has been amended to expand the information that an assessor can request from taxpayers regarding preparation of assessments.
Canada
2 Oct 2018
19
Tax Court Affirms Treaty-Based Canadian Holding Structure
The Tax Court of Canada recently held, in Alta Energy Luxembourg SARL v R, 2018 TCC 152, that a Luxembourg S.A.R.L was entitled to treaty benefits on capital gains...
Canada
9 Sep 2018
20
Countering The Countermeasures Mitigation Strategies For Importers
Since July 1, 2018, Canada has imposed 25% and 10% ad valorem surtaxes on the importation of a wide variety of U.S. "originating" goods.
Canada
24 Jul 2018
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