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1
Whistleblowing Pays Off—New CRA Data On First Payments To Informants
The Canada Revenue Agency's (CRA) Offshore Tax Informant Program (OTIP) is a whistleblower program that rewards eligible individuals who come forward to provide CRA with information
Canada
26 Aug 2019
2
Bennett Jones On Tax Disputes - August 2019
The latest edition of Bennett Jones on Tax Disputes, published on Taxnet Pro by Thomson Reuters,...
Canada
19 Aug 2019
3
Tax Court Affirms Treaty-Based Canadian Holding Structure
The Tax Court of Canada recently held, in Alta Energy Luxembourg SARL v R, 2018 TCC 152, that a Luxembourg S.A.R.L was entitled to treaty benefits on capital gains...
Canada
9 Sep 2018
4
New Non-Resident Speculation Tax In Ontario
Residential property, for the purposes of the non-resident speculation tax, includes land that contains at least one and not more than six single family residences.
Canada
26 Apr 2017
5
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
6
Lincoln Caylor: Report A Canadian Tax Evader And Make Money?
Yes, it's possible. Canada has had a tax whistleblower program for four years, the Offshore Tax Informant Program (OTIP).
Canada
7 Mar 2017
7
Toronto Municipal Land Transfer Tax Increase
The City of Toronto has increased its municipal land transfer tax rates to match the recent changes to provincial land transfer taxes, effective March 1, 2017.
Canada
6 Mar 2017
8
Rio Tinto Alcan v. The Queen: Welcome Expansion Of The Canadian Tax Deductibility Of M&A Transaction Expenses
In a welcome decision for Canadian acquirors and targets, the Tax Court of Canada recognized, in Rio Tinto Alcan Inc. v The Queen,1 that certain oversight expenses—including certain investment banking...
Canada
2 Mar 2017
9
CRA Releases New Guidelines Regarding Canadian Exploration Expenses
On the heels of some recent positive legislative changes regarding the tax treatment of environmental study and community consultation costs, the Canada Revenue Agency (CRA)...
Canada
23 Feb 2017
10
SCC Confirms General Intention Not Sufficient For Rectification In Tax Cases
On December 9, 2016, the Supreme Court released its decisions in two tax rectification cases: Jean Coutu Group (PJC) Inc. Canada (Attorney General), 2016 SCC 55...
Canada
16 Dec 2016
11
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
12
Ontario Modernizing Land Transfer Tax
On November 14, 2016, the Ontario Minister of Finance, Charles Sousa, presented the 2016 Ontario Economic Outlook and Fiscal Review in the Ontario Legislature.
Canada
21 Nov 2016
13
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
14
Ministry Of Finance Ready To Party Like It's 1989: Retroactive Changes To Ontario Provincial Land Transfer Tax
On February 18, 2016, the Ministry of Finance filed a new regulation under the Land Transfer Tax Act which purports to be retroactive to July 19, 1989 (O. Reg. 35/16).
Canada
1 Mar 2016
15
Secured Creditors Can Appeal To Tax Court On Behalf Of A Bankrupt
The Tax Court of Canada recently confirmed that in certain circumstances a secured creditor can commence or continue a tax appeal on behalf of a bankrupt estate.
Canada
9 Dec 2014
16
CRA Required To Reassess In Accordance With Terms Of Settlement
The decision in Bolton Steel Tube Co. Ltd. v. The Queen confirms that the CRA is required to reassess a taxpayer in accordance with terms of settlement.
Canada
30 Jul 2014
17
Roitelman: Director Not Liable Where Employee Engages In Deceit
Can a director establish a due diligence defence with respect to unremitted source deductions where the responsibility for remittance lay with an employee?
Canada
25 Jul 2014
18
CRA Owes A Duty Of Care To Taxpayers
While taxpayers have initiated a number of civil claims against the CRA, alleging everything from negligence to fraud, these claims are rarely successful.
Canada
21 Jul 2014
19
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
20
Businesses Face More Onerous Transfer Pricing Documentation And Country-By-Country Tax Reporting
The OECD proposes to reform transfer pricing documentation for multinational enterprises and to impose onerous country-by-country reporting obligations.
Canada
10 Mar 2014
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