Searching Content indexed under Transfer Pricing by Blake, Cassels & Graydon LLP ordered by Published Date Descending.
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Legal Trends 2016: Tax
Elected in October 2015, Canada's new Liberal government has proposed a tax platform featuring significant changes, including a four per cent increase (to 33 per cent) in the federal tax rate for individuals on income over C$200,000 and a 1.5 per cent drop in the middle-income tax rate.
14 Apr 2016
2016 Federal Budget – Selected Tax Measures
On March 22, 2016, the Minister of Finance tabled Canada's 2016 Federal Budget (the 2016 Budget).
4 Apr 2016
Selected International Measures From August 2014 Legislative Proposals
On August 29, 2014, the Minister of Finance released for consultation draft legislative proposals to amend the Income Tax Act (Canada).
9 Sep 2014
Procedural Disputes in Canadian Transfer Pricing and Tax Avoidance Cases – Are You Prepared?
Over the last few years, there has been an increase in the number of procedural disputes making their way through Canadian courts as part of the tax resolution process.
17 Jan 2011
Pension Law Regulatory Update and New Case Developments
In 2005, the law on pensions and employee benefits has continued to see significant changes implemented or proposed. Here are some of the most recent pension and benefits cases, as well as developments in Canadian legislative and regulatory policy.
5 Oct 2005
Legal Challenges in Converting to Defined Contribution Pension Plans
Employers that want to provide defined contribution pension plans (DCPPs) face administrative and other challenges not found with defined benefit pension plans (DB Plans). Many of these challenges stem from a lack of clarity in the law on DCPPs and legal issues, ranging from improper member communications to structuring funding arrangements, can arise.
5 Oct 2005
Canadian International Trade Tribunal Continues Anti-Dumping Order After 21 Years Of Protection
On September 12, 2005, the Canadian International Trade Tribunal (Tribunal) released its statement of reasons continuing, with amendment, an anti-dumping order concerning whole potatoes imported from the United States (U.S.) for use or consumption in British Columbia (B.C.). With the amendment, the Tribunal excluded from its order certain potato types and pack sizes.
28 Sep 2005
Cross-Border Guarantees — Some Transfer Pricing Relief
Transactions entered into between a Canadian taxpayer or partnership and a non-arm’s length non-resident are generally subject to the transfer pricing rules contained in section 247 of the Income Tax Act.
13 Apr 2005
Do’s And Don’ts Of IT Licensing — Top 10 Tips
What are the risks, issues and contractual terms to be aware of for technology license agreements? To create effective licenses for both licensors and licensees, it is important to have an understanding of the common legal and business issues that arise in negotiating licenses by following these "Top 10" tips. Software, Web sites, e-commerce transactions and information technology generally can involve many different forms of intellectual property (IP).
10 Nov 2004
Federal Court Of Appeal And GAAR – Good News/Bad News
The Federal Court of Appeal (FCA) recently dismissed the Crown’s appeals in Canada Trustcoand Imperial Oil with respect to the application of the general anti-avoidance rule (GAAR) in the Canadian Income Tax Act.
16 Jul 2004
Applying The Transfer Pricing Rules To Guarantees
At the time Canada was amending its transfer pricing rules, much concern – and some confusion – arose over the potential application of the rules to financial transactions. This was particularly the case where the tax consequences of applying those rules to financial transactions were already regulated under other provisions of the Canadian Income Tax Act.
5 Jul 2004
Foreign Franchisors Expanding Into Canada
Canada continues to be the most important market for US franchisors operating outside of the US. The regulatory regime in Canada aimed specifically at franchising is much less developed and, accordingly, much less restrictive than in the US. Most franchised businesses involve retail restaurants, services, or sale of consumer goods, all of which usually rely heavily on their locations and the real estate related to those locations.
7 May 2004
Taxes On The Transfer And Leasing Of Real Property In Canada
The transfer of real property is subject to a land transfer tax in most, but not all, provinces in Canada
16 Mar 2004
Getting And Giving Third Party Taxpayer Information
The Canadian income tax system is based on the principles of self-reporting and self-assessment. At first instance, the government does not have sufficient information to determine each person’s income or tax. Accordingly, taxpayers are trusted to report their own income for each year. In order to ensure accuracy of returns, the Canada Customs and Revenue Agency (CCRA) is given broad powers to audit taxpayers’ books and records and obtain other information.
18 Feb 2004
Foreign-Based Information
Tax executives and practitioners familiar with administrative procedures under the Canadian Income Tax Act (the "Act") are aware of the broad powers afforded the Canada Customs and Revenue Agency ("CCRA") to conduct audits, to compel the production of books and records and even to obtain and execute search warrants
18 Feb 2004
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