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Searching Content indexed under Income Tax by Borden Ladner Gervais LLP ordered by Published Date Descending.
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1
New Developments Regarding The Application Of Registered Plan Advantage Rules
Recent developments regarding taxes on investments placed in registered plans provide further guidance on the ways in which taxpayers can and cannot use these accounts to invest
Canada
9 Dec 2019
2
Supreme Court Of Canada Won't Reconsider The GAAR In Birchcliff Energy Ltd.
On November 14, 2019, the Supreme Court of Canada denied the taxpayer's application for leave to appeal from judgment of the Federal Court of Appeal in Birchcliff Energy Ltd. v The Queen, 2019 FCA 151.
Canada
27 Nov 2019
3
The Billionaire's Audit: Québec Taxpayer Awarded Damages For Negligent RPI Audit
In 2005, the Canadian Revenue Agency (CRA) launched the Related Party Initiative (RPI), more commonly referred to as the High-Net-Worth Project or the Billionaire's Audit.
Canada
26 Nov 2019
4
What To Refuse? Ontario Court Clarifies Scope Of Discovery Of A Representative Plaintiff
In Lipson v. Cassels Brock & Blackwell LLP, Justice Perell revisited the scope of examinations for discovery in class action proceedings.
Canada
25 Nov 2019
5
Misrepresentation Of Business Expenses Exposes Taxpayer To Reassessment Beyond Normal Reassessment Period
Following a reassessment raised on November 19, 2018, the defendant (Taxpayer) was denied business expenses claimed for his 2013 ($6,104), 2014 ($4,246) and 2015 ($3,929) taxation years
Canada
21 Oct 2019
6
Taxpayer Relief – T1135
Canadian residents2 who own specified foreign property (SFP) that has a cost of over $100,000 during the year must complete form T1135, ...
Canada
23 Sep 2019
7
Tournier v. The Queen 2018 TCC 229
The taxpayer practiced as a lawyer for 27 years before ultimately retiring from the profession in 2013. In preparation for retirement,...
Canada
23 Sep 2019
8
Husky Oil – Tax Court Reaffirms Basic Rules Of A Pleading
​Tax litigation can be a very complex process. Many of the rules and procedures that govern tax disputes are designed to match the mechanics of the federal tax system in Canada, including GST/HST
Canada
22 Aug 2019
9
Mutual Fund Trusts — Revised Proposals Relating To Allocation To Redeemers
This year's federal budget contained proposed amendments to the Income Tax Act (Canada) (Tax Act) that targeted the "allocation to redeemers" methodology used by certain mutual fund trusts and unit trusts (the Budget Proposals).
Canada
9 Aug 2019
10
Upcoming Changes To The Taxation Of Employee Stock Options
In Budget 2019, the Government of Canada announced its intention to limit the current employee stock option tax regime, moving towards aligning Canada's tax treatment of such options with the United States
Canada
10 Jul 2019
11
Non-Residents Of Canada Not Required To Disclose Books And Records To The CRA
The Minister of National Revenue (the Minister) sought an order from the Federal Court to compel three individuals to provide the Canada Revenue Agency with books, records and information required
Canada
31 May 2019
12
Advance Tax Credit Financing
From a cash flow perspective, many corporations in need of liquidities cannot afford to wait until the end of the fiscal year to receive payment of refundable tax credits.
Canada
25 Apr 2019
13
Federal Budget 2019 – Impact On Charities And Non-Profit Organizations
The Government's 2019 Federal Budget was tabled yesterday. There were no tax measures affecting charities and non-profit organizations, including no mention of the Government's proposed review
Canada
1 Apr 2019
14
Federal Budget 2019 — No Real Surprises
The Honourable William Morneau, Minister of Finance, tabled the 2019 Federal Budget (Budget 2019) for the Government of Canada (the Government) on March 19, 2019 (Budget Day).
Canada
1 Apr 2019
15
Political Activities Update For Registered Charities
The Liberal Government recently announced that it has withdrawn its appeal of the decision of the Ontario Superior Court in Canada Without Poverty v. Attorney General of Canada,
Canada
14 Feb 2019
16
Canadian FATCA And CRS Compliance Updates
It has now been almost five years since Canada entered into the Canada-United States Enhanced Tax Information Exchange Agreement (the IGA), which was implemented by the Canada-United States...
Canada
12 Dec 2018
17
Time To Act Before Year End: Corporate RDTOH Planning Opportunities
Currently, through the operation of the refundable dividend tax on hand (RDTOH) rules, a portion of the tax paid on passive income earned by a private corporation is refunded when the corporation pays dividends.
Canada
10 Dec 2018
18
CRA's Power To Compel Taxpayers To Disclose Uncertain Tax Positions Affirmed
Canada (National Revenue) v Atlas Tube Canada ULC1 is the latest in a series of cases considering the ability of the Canada Revenue Agency (CRA) to compel corporate disclosure of confidential reports analyzing the tax positions of a company.
Canada
21 Nov 2018
19
Taxpayer Wins Convincing Decision In Landmark Canadian Transfer Pricing Case
Relevant to: Multinational groups with Canadian subsidiaries or a Canadian parent corporation, and other Canadian residents who engage in transactions with non-residents of Canada...
Canada
4 Oct 2018
20
Court Declares 10 Per Cent Limit On Political Activities By Charities Unconstitutional
The lack of clarity with the rules surrounding political activities of registered charities, and their application, has been an ongoing concern in the charitable sector.
Canada
30 Aug 2018
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