Federal Budget 2014
Previously Announced Measures
The Government intends to proceed with the following previously announced tax and related measures, as modified to take into account consultations and deliberations since their release: Proposed changes to certain GST/HST rules relating to financial institutions released on January 28,...
Introduction
Minister of Finance Jim Flaherty today tabled the 2013 Federal Budget (the “Budget”) entitled Jobs, Growth and Long-Term Prosperity – Economic Action Plan 2013. We are pleased to provide our summary of tax measures contained in the Budget. The Budget...
MGM Shows Lion-like Persistence in Protecting Roar
International Trademark Association Bulletin
Tax Treatment of Break Fees From Recipient’s Perspective
The Tax Court of Canada (the “TCC”) considered the tax treatment of break fees in Morguard Corporation v. The Queen (2012 TCC 550) (“Morguard”) for purposes of the Income Tax Act (Canada) (the “Act”) from the recipient’s perspective. The taxpayer...
Beneficial Ownership Test For Tax Treaty Benefit Entitlement
In Velcro Canada Inc. v. Her Majesty the Queen (2012 TCC 57), the Tax Court of Canada (the “TCC”) applied the test of beneficial ownership as established by the Federal Court of Appeal in Prévost Car Inc. v. Canada (2009...
CCPC Status Preserved Through Unanimous Shareholders’ Agreement
In the recent case of Price Waterhouse Coopers Inc. Agissant Ès Qualité de Syndic à la Faillite de Bioartificial Gel Technologies (Bagtech) Inc. v. The Queen (2012 CCI 120) (“Bagtech”), the Tax Court of Canada (the “TCC”) ruled that Bagtech...
Capital Gains Exemption: Effects of Irregularities in Corporate Records
The recent decision of the Tax Court of Canada (the “TCC”) in Twomey v. Her Majesty the Queen (2012 TCC 310) highlights the importance of strict compliance with the technical provisions of the Income Tax Act (Canada) (the “Act”), as...
Tax Court of Canada Rules on Location of Business Income For Tax Exemption Under Indian Act
On July 10, 2012, the Tax Court of Canada (the “TCC”) released its judgment in Dickie v. The Queen (2012 TCC 242) wherein Miller Thomson was successful in having a reassessment under the Income Tax Act (Canada) (the “Act”) vacated. ...
International Tax Update
International Tax Newsletter
View the November 2012 issue.
