Searching Content indexed under Wealth Management by Gowling WLG ordered by Published Date Descending.
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Owning French Real Estate In Trust
Although the concept of a trust does not exist in the French Civil Code, French law does not prohibit the ownership of assets, in particular French real estate, through trusts.
10 Jan 2017
Reforms To The Taxation Of Non-UK Domiciled Individuals: Draft Legislation And Final Proposals
On Monday 5 December 2016, the Government published long-awaited draft legislation for the reform of the taxation of non-UK domiciled individuals....
15 Dec 2016
Non-Dom Tax Changes - No Respite In The Autumn Statement
In his Autumn Statement yesterday, the UK Chancellor, Philip Hammond, confirmed that proposed tax changes targeted at non-domiciled individuals that were first announced at the Summer Budget in 2015...
29 Nov 2016
The Impact Of The Autumn Statement On Private Capital
As expected, the Chancellor has announced that the changes to the taxation of non-domiciliaries will proceed in April 2017.
28 Nov 2016
French Tax Legislation Applicable To Trusts: Positive Developments Regarding Penalties
Article 1736 IV bis of the French Tax Code (FTC) imposes very high penalties for trustees who fail to comply with filing requirements imposed by French tax legislation applicable to trusts.
19 Sep 2016
Reforms To The Taxation Of Non-Domiciled Individuals: Updated Proposals
The Government published its long-awaited follow-up consultation on the proposals for reform of the taxation of non-UK domiciled individuals, which were initially announced at the Summer Budget in July 2015.
7 Sep 2016
New Penalty To Support The Common Reporting Standard
Canada is now implementing a new international standard for the automatic exchange of financial account information between tax administrations referred to as the common reporting standard.
5 Sep 2016
Urgent Advisory: Commence Voluntary Disclosures Before The End Of 2015
Data from the Canada Revenue Agency ("CRA") confirms that voluntary disclosures ("VDs") of offshore assets, gains and income hit record levels in 2015.
16 Dec 2015
Le budget de 2014 – objectif : intégrité
Le ministre des Finances Jim Flaherty s’enorgueillit du nombre de mesures d’intégrité qu’il a introduites depuis 2006.
12 Feb 2014
Budget 2014: Fiscal Integrity As A Work In Progress
Minister of Finance Flaherty takes pride in the integrity measures he has introduced since 2006. Last year, Budget 2013 touted over 75 measures aimed at improving integrity and closing tax loopholes
12 Feb 2014
Canadian Tax @ Gowlings - November 22, 2010 - Special Bulletin
On November 17, 2010, the Federal Court of Appeal ("FCA") released its reasons for judgment in the St. Michael Trust Corp. appeal, upholding the judgment of Woods J. of the Tax Court of Canada ("TCC") in the Garron Family Trust case.
29 Nov 2010
Taxation Law @ Gowlings - November 16, 2009
The Income Tax Act does not provide a formula for determining the residency of a trust. Instead, the development of a test of trust residence in Canada has been left to the courts.
18 Nov 2009
Migrating IP Offshore Within A Transfer Pricing Setting
If a multinational corporation had the luxury of perfect hindsight, it would optimize its global positioning and operational efficiencies by migrating intangible assets prior to those assets proving valuable.
2 Oct 2007
Taxation Of Trust Capital Securities: Is There A Pending Battle Between The Government And Canada´s Financial Institutions?
The recent announcement by the Government of Canada that it would begin taxing distributions of income trusts and other "specified investment flow-throughs" ("SIFT") has brought planned conversions of corporations such as Telus and BCE into income trusts to a grinding halt and, for some investors, has impeded an investment vehicle with considerable value.
9 Mar 2007
Rectification Order Can Bail Out The Misguided Taxpayer
If implementing a plan to save tax turns around and instead causes an unintended tax liability, it may be possible to fix the problem with a rectification order. The Court can retroactively alter documents or agreements with a rectification order to actualize the taxpayer's real intention and thereby prevent the Canada Revenue Agency ("CRA") from benefiting from the taxpayer's (or the advisor's) mistake and enjoying an unexpected windfall.
23 Nov 2006
Jim Flaherty´s Scary Halloween Trick
Just as little trick or treaters were heading out to try their luck on Halloween evening, Jim Flaherty performed an unexpected trick of his own he announced the wholesale overhaul of Canada's income and royalty trust market.
9 Nov 2006
Migrating Intangibles: More Complex Than Just the Movements of Functions, Assets, and Risks
Recently, there have been significant discussions regarding government crackdowns on tax havens related to multinational organizations moving profits offshore. From a tax perspective, any financial planning that involves moving profits offshore by multinational organizations is justifiable if the corresponding functions, assets, and risks borne to earn these profits are also shifted offshore.
14 Jul 2006
Difficult to Apply and Hard to Avoid: Canada’s Foreign Investment Entity (FIE) Rules
In response to a perceived increase in the use of offshore investment structures to avoid Canadian income tax, the Department of Finance first introduced complex tax legislation that governs the treatment of direct or indirect investments in certain foreign entities by Canadian taxpayers (the FIE Rules) in 2001.
4 Apr 2006
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