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Article :: 2018 Canadian Federal Budget Commentary – Tax Initiatives
On February 27, 2018 (Budget Day), Finance Minister Bill Morneau tabled in the House of Commons the Liberal Government's third budget, Equality & Growth: A Strong Middle Class (Budget 2018).
1 Mar 2018
2017 Canadian Federal Budget Commentary – Tax Initiatives
On March 22, 2017 (Budget Day), Finance Minister Bill Morneau tabled in the House of Commons the Liberal Government's second budget, Building a Strong Middle Class (Budget 2017).
23 Mar 2017
2016 Canadian Federal Budget Commentary – Tax Initiatives
On March 22, 2016 (Budget Day), Finance Minister Bill Morneau tabled in the House of Commons the new Liberal Government's first budget, Growing the Middle Class (Budget 2016).
4 Apr 2016
Anson V. HMRC: Another Approach To LLCs
The facts in the case may be summarised as follows. The taxpayer in the case (Anson) was a non-domiciled UK resident and member of an LLC which carried on the business of managing venture capital funds in the US.
4 Dec 2015
BEPS Final Reports: An Update On Treaty Shopping
The Organisation for Economic Co-operation and Development (OECD) sees treaty shopping as an important source of Base Erosion and Profit Shifting.
3 Dec 2015
Economic Action Plan 2015 – The Election Budget
On April 21, Finance Minister Joe Oliver tabled in the House of Commons his first budget, Economic Action Plan 2015, and the one that the Conservatives will take to the polls.
22 Apr 2015
B.C. Government Tables Amendments To LNG Tax Legislation
In a previous blog entry, we provided comprehensive commentary on the then-recently tabled Liquefied Natural Gas Income Tax Act.
30 Mar 2015
Major Changes To Québec’s Mining Tax Regime
Following several months of uncertainty since the announcement of modifications to the Québec mining tax regime, the Québec Minister of Finance and the Economy, Nicolas Marceau, together with the Québec Minister of Natural Resources, Martine Ouellet, have finally announced the amendments that they propose to make to the Mining Tax Act.
22 May 2013
Canadian "Thin Capitalization" Rules: Further Broadening
Canada, like many developed countries, restricts the amount of interest a corporation resident in Canada may deduct on loans made by non-residents who are the CRIC’s significant shareholders or their affiliates.
15 May 2013
Orca Sand & Gravel Limited Partnership v. British Columbia, 2012 BCSC 1402
This decision underlines the importance of how mining equipment is used for purposes of exemptions from taxation under the British Columbia "Social Service Tax Act".
21 Mar 2013
The Second Opinion: BCCA Finds Limited Partners Not Purchasers Of Property Sold To Limited Partnership
When a limited partner sells property to the limited partnership, is the limited partner itself a purchaser of that property, or is the only purchaser the general partner on behalf of the limited partnership?
4 Mar 2013
A Commentary On Recent Legal Developments By The Opinions Group Of Mccarthy Tétrault LLP
This week, the Supreme Court of Canada heard arguments in one case likely to be of interest to Canadian businesses and professions.
28 Feb 2013
Highlights From The Québec Government's 2013-2014 Budget Relating To Businesses
Under this new program, corporations and partnerships that begin to carry out a large investment project in Québec after November 20, 2012 may, under certain circumstances, obtain a ten-year tax holiday.
4 Dec 2012
Budget 2012 Legislation - More Revisions To Foreign Affiliate "Dumping" And Shareholders Loan Rules
On October 15, 2012, the Minister of Finance (Canada) tabled a Notice of Ways and Means Motion (NWMM) in the House of Commons to implement certain measures from the March 29, 2012 Federal budget (Budget 2012) that were amended in draft legislation released on August 14, 2012 (August Proposals).
26 Nov 2012
More On FATCA … And More To Come: The Internal Revenue Service And Treasury Department Release Proposed Regulations
In 2010, the United States amended the Internal Revenue Code of 1986 to add provisions relating to foreign account tax compliance (FATCA).
13 Apr 2012
Harper’s First Majority Government Budget – Tax Changes Include Targeted Measures To Close Perceived Loopholes
The Honourable James M. Flaherty, Minister of Finance, introduced the Harper government’s first majority budget (Budget 2012), entitled Economic Action Plan 2012: Jobs, Growth and Long-Term Prosperity, on March 29, 2012.
9 Apr 2012
Anti-Discrimination And The Canada-UK Tax Treaty
Saipem UK Limited v. the Queen is the first Canadian case wherein the Tax Court of Canada has decided with respect to the anti-discrimination provisions contained in a Canadian tax convention, being Article 22 of the Convention Between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland (Treaty).
11 Mar 2011
Late-Filing Penalties for Non-Resident Corporations
On June 11, 2010, the Federal Court of Appeal in " Ltd. Liability Co. v. Her Majesty the Queen" (2010 DTC. 6935) resolved two conflicting decisions of the Tax Court of Canada on the issue of whether a non-resident corporation that does not have any tax payable under the "Tax Act" may be subject to a late-filing penalty for failing to file an income tax return within the prescribed time in the "Tax Act".
4 Nov 2010
US LLCs May Claim Refunds in Certain Circumstances
The Canada Revenue Agency (CRA) recently announced that it will accept claims for treaty benefits by US limited liability companies (LLCs) in certain circumstances.
4 Nov 2010
Quebec’s Budget Calls for Increased Taxpayer Participation
On March 30, 2010, the Quebec Finance Minister, Raymond Bachand, tabled Quebec’s 2010-2011 budget in the National Assembly (Budget).
13 Apr 2010
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