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Searching Content indexed under Corporate Tax by Bennett Jones LLP ordered by Published Date Descending.
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1
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
2
Status Of Measures Targeting Private Corporations Following The 2018 Federal Budget
The Federal Budget, released February 27, 2018, has clarified federal plans to change the tax treatment of private corporations and represents a substantial retreat from proposals announced in July 2017.
Canada
14 Mar 2018
3
No Routine Access By CRA To Tax Working Papers Rules The Federal Court Of Appeal
The Federal Court of Appeal has limited the Canada Revenue Agency's (CRA) access to tax accrual working papers that reveal a taxpayer's uncertain tax positions.
Canada
18 Apr 2017
4
What Trump's Tax Plan Means For Canada
The election of Donald Trump combined with Republican control of Congress means that U.S. tax reform has suddenly gone from totally impossible to highly likely.
Canada
21 Nov 2016
5
Tax Uncertainty Hinders Global Growth: Business Survey Launched
Businesses are invited to participate in an international survey from the OECD to measure the impact of tax uncertainty on their investment decisions.
Canada
8 Nov 2016
6
Tax Court Allows Deduction For Advisory Fees In M&A Transaction
The Canada Revenue Agency has traditionally taken a hard line on expenses incurred by an acquirer or a target and has denied deductibility on the basis that these expenses are of a capital nature.
Canada
26 Jul 2016
7
Federal Court Of Appeal Clarifies Test For "De Facto Control"
The FCA's clarification in McGillivray should have the practical effect of providing a higher level of certainty and comfort to taxpayers seeking advice on this important and pervasive issue in a variety of circumstances.
Canada
27 Apr 2016
8
Panama Papers Leaks: Do You Know Your Exposure?
The "Panama Papers" story hit the international press this week. An anonymous source leaked 11.5 million documents from Mossack Fonseca, the Panamanian firm believed to be the world's fourth largest provider of offshore legal services.
Canada
12 Apr 2016
9
Supreme Court Of Canada Grants Leave To Appeal In Fairmont Hotels Inc.
The granting of leave seems to signal that the Supreme Court is prepared to consider the question of whether the decision in Juliar v Canada is good law and should govern requests for rectification in tax cases.
Canada
16 Dec 2015
10
Ontario Court Follows Juliar And Allows Rectification Of A Series Of Transactions
In Canada Life, a Canadian subsidiary (Canada Life) received $3.5 billion of investment assets from its ultimate parent, which included a portfolio of U.S. dollar bonds.
Canada
1 Dec 2015
11
Supreme Court Of Canada To Hear Tax Rectification Case
On November 19, 2015, the Supreme Court of Canada granted leave to appeal in Canada (A.G.) v. Groupe Jean Coutu (PJC) inc., 2015 QCCA 838, which addresses the question of when rectification will be granted in the tax context.
Canada
25 Nov 2015
12
Appeal Court Confirms Tax Advisors Do Not Owe Common Law Duty To Indemnify
The Alberta Court of Appeal confirmed that tax advisors do not owe a common law duty of contribution and indemnity to recipients of their tax advice when that advice turns out to be wrong.
Canada
9 Feb 2015
13
Rectification Is About Intention – Not Interpretation
The Ontario Superior Court of Justice recently granted rectification in a case in which the CRA and the taxpayer differed in their interpretation and effect of a particular document.
Canada
29 Jan 2015
14
Canadian Importers May Now Seek Import Duty Refunds
Since the introduction of the Transaction Value System of customs valuation by Canada on January 1, 1985, the Canada Border Services Agency (CBSA) has maintained a stated policy of denying refund claims of related party importers who seek to amend declared values for duty to account for adjustments that decrease transfer prices after importation.
Canada
20 Jan 2015
15
BEPS Tail Shouldn’t Wag Global Investment Dog
I spoke recently on a panel in Tokyo on the future of international tax planning after BEPS (the OECD’s & G20’s Action Plan to counter Base Erosion & Profit Shifting).
Worldwide
26 Nov 2014
16
Tax Effective Use By Canadian Online Retailers Of Bermuda Operations For International Expansion
The growth of online retail sales has globally outstripped the growth of all other retail channels, including during the last recession.
Canada
16 Jun 2014
17
Department Of Finance Releases Consultation Paper On Anti-Treaty Shopping Measures
In the March 2013 Federal Budget, the Department of Finance indicated that it intended to initiate a consultation process on certain "treaty shopping" practices.
Canada
11 Sep 2013
18
OECD Launches Action Plan On Base Erosion And Profit Shifting
The OECD has recently released its Action Plan on Base Erosion and Profit Shifting.
Canada
25 Jul 2013
19
International Tax & Transfer Pricing Strategies In The Crosshairs
The OECD recently issued a report targeting corporate tax planning and transfer pricing strategies, which it asserts constitute a serious risk to tax revenues, tax sovereignty among nations and tax fairness.
Canada
28 Feb 2013
20
Foreign-Controlled Canadian Corporations Beware
On August 14, 2012, the Department of Finance released draft legislation that includes a revised version of the foreign affiliate dumping proposals tabled with the March 29 Federal Budget.
Canada
5 Oct 2012
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