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Searching Content indexed under Wealth & Asset 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.
France
10 Jan 2017
2
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.
UK
7 Sep 2016
3
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.
Canada
 
29 Nov 2010
4
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.
Canada
 
18 Nov 2009
5
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.
Canada
 
2 Oct 2007
6
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.
Canada
9 Mar 2007
7
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.
Canada
23 Nov 2006
8
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.
Canada
 
9 Nov 2006
9
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.
Canada
14 Jul 2006
10
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.
Canada
4 Apr 2006
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