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Searching Content indexed under Income Tax by Fogler, Rubinoff LLP ordered by Published Date Descending.
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Cross Border Tax — Regulation 105: Part I
Regulation 105 to Paragraph 153(1)(g) of the Income Tax Act (Canada) requires a Canadian customer of a non-resident
Canada
5 Sep 2019
2
Daniel LaPlante v. The Queen: Family Trusts And Corporate Transactions Gone Awry
Many trustees do not follow the legalities surrounding family trusts in corporate transactions. On a share sale transaction, the trustees (often one or both of the patriarch or matriarch....
Canada
12 Jun 2019
3
The New Refundable Dividend Tax On Hand Regime
Starting on January 1, 2019, Canadian controlled private corporations earning investment income will be subject to a new set of complex tax rules relating to their refundable dividend tax on hand ("RDTOH") balance.
Canada
28 Jan 2019
4
Dividend Allocations To A Corporate Beneficiary Subject To Part Iv Tax In A Share Sale Transaction
In CRA Technical Interpretation 2016-0647621E5, June 3, 2016, "Part IV Income Tax - Dividend Paid to a Corporate Trust Beneficiary", the CRA held that Part IV tax would apply on an allocation of dividends...
Canada
28 Dec 2018
5
Section 7 And "Agreement" — There Must Be A Legally Binding Agreement
In Transalta v. The Queen (2012 DTC 1106) ("Transalta"), the Tax Court of Canada concluded that for the stock option rules ...
Canada
16 Oct 2018
6
Univar Holdco Canada Ulc V. Canada - The Relevance Of Alternative Transactions, Subsequent Amendments And Finance Commentary To The Gaar Analysis
On October 13, 2017, the Federal Court of Appeal released its decision in Univar Holdco Canada ULC v. Canada, 2017 FCA 207.
Canada
27 Mar 2018
7
Revised Income Splitting Proposals
On July 18, 2017, the Department of Finance released a series of controversial tax proposals aimed at closing perceived tax "loopholes" that involve the taxation of private corporations and their shareholders.
Canada
20 Dec 2017
8
Significant Restrictions To The Voluntary Disclosures Program
The Voluntary Disclosures Program (VDP) is a "tax amnesty" program administered by the Canada Revenue Agency ("CRA"). It allows noncompliant taxpayers to voluntarily correct their tax affairs...
Canada
17 Oct 2017
9
Major Proposed Changes To The Taxation Of Private Corporations And To Severely Limit Income Splitting
The Federal Government released a set of proposals on July 18, 2017 that, in the government's words, are designed to "improve fairness in the tax system by closing loopholes and addressing...
Canada
20 Jul 2017
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