Canadian Renewable & Conservation Expense “Green” Energy Tax Incentives
This article is an overview of the Canadian income tax considerations relevant to Canadian renewable and conservation expenses (“CRCE”) initially introduced in the March 1996 Canadian Federal Budget as a new category of deductible expenses and related recent amendments included...
Overview of Limitation on Benefits Article in Canada-U.S. Tax Treaty
The Canada-United States Tax Treaty (the “Tax Treaty”) is unique among Canada’s tax treaties in its approach to prevent “treaty shopping”. Treaty shopping generally refers to the acquisition and enjoyment of treaty benefits under a given tax treaty by persons...
SCC Tax Cases 2012 in Review: The Death of Moldowan and the First Transfer Pricing Decision
There are only a few tax cases that make it to the Supreme Court of Canada (“SCC”). Indeed, any party that has sought leave to appeal to the SCC knows only too well that it is an exceptionally difficult task....
Overview of New Canada-Hong Kong Tax Treaty
On November 11, 2012, the Government of Canada signed a tax treaty with the Government of the Hong Kong Special Administrative Region of the People’s Republic of China (referred to herein as “Hong Kong”) for the avoidance of double taxation...
Canadian Tax Treatment of Mortgage Investment Corporations and Their Shareholders
A mortgage investment corporation (“MIC”) and its shareholders are entitled to special tax treatment under section 130.1 of the Income Tax Act (Canada) (the “Act”). These special rules were introduced to attract more money to the Canadian mortgage market for...
Recent Proposed Changes to Rules Applicable to Personal Services Business
Back in the 1970s, while the Montreal Canadiens were dominating the NHL, Ken Dryden backstopped the Canadiens to win six Stanley Cups. While much can be said about Ken Dryden’s heroics in winning the Stanley Cup, this is, after all,...
Using the Oppression Remedy to Enforce Unpaid Corporate Judgments
Tax for the Owner-Manager, Canadian Tax Foundation, April 2013
Ease Funding Challenges with Letters of Credit
Benefits Canada, April 2013
Personal Income Tax Measures
IN THIS SECTION: Synthetic Dispositions Character Conversion Transactions Trust Loss Trading Non-Resident Trusts Consultation on Graduated Rate Taxation of Trusts and Estates Registered Pension Plans: Correcting Contribution Errors Labour-Sponsored Venture Capital Corporations Tax Credit Lifetime Capital Gains Exemption Dividend Tax...
Business Income Tax Measures
IN THIS SECTION: Leveraged Life Insurance Arrangements Corporate Loss Trading Taxation of Corporate Groups Mining Expenses Restricted Farm Losses Reserve for Future Services Additional Deduction for Credit Unions Manufacturing and Processing Machinery and Equipment: Accelerated Capital Cost Allowance Clean Energy...
