A New Era of Private Corporation Tax Rules – Part V
It has been just over a year since the federal Department of Finance (“Finance”) released revised draft amendments to the tax on split income (“TOSI”) rules in section 120.4 of the Income Tax Act (Canada) (the “Act”) that “simplified” the...
Callidus Capital Corporation v Her Majesty the Queen SCC Appeal Granted
In a rare move, the Supreme Court of Canada has allowed the Callidus Capital Corporation appeal from the bench. This appeal involved the priority between secured creditors and the Canada Revenue Agency under the Excise Tax Act once a tax...
Highlights of the USMCA
On September 30, 2018, the United States, Mexico and Canada reached a new trade agreement, the United States–Mexico-Canada Agreement (“USMCA”). This agreement maintains a free-trade zone between the three countries and could be signed prior to December 1, 2018. The...
Excise Tax Act Amendments Released July 2018
On July 27, 2018, the Department of Finance (“Finance”) released the Legislative and Regulatory Proposals Relating to the Excise Tax Act (Canada) (the “ETA”), including amendments to sections 186 and 289.2 and subsection 292(7) (the “Proposals”). Section 186 – Holding...
Ron Choudhury and Andrew Etcovitch quoted in Bloomberg article on input tax credit limits for holding companies
Bloomberg, "Canada Plans to Limit Input Tax Credits for Holding Companies"
The Canadian government has proposed limiting the amount holding companies can recover from value-added and sales tax they pay on goods and services purchased for an operating subsidiary. […] This will have limited application to foreign multinationals, as it only applies...
A New Era of Private Corporation Tax Rules – Part IV
On June 21, 2018 Bill C-74, An Act to implement certain provisions of the budget tabled in Parliament on February 27, 2018 and other measures (“Bill C-74”) received Royal Assent. Bill C‑74 includes various amendments to the Income Tax Act...
Canada-U.S. Trade War? Canada Retaliates with New Tariffs on U.S. Goods
On June 29, 2018, the Canadian Government announced that it would implement countermeasures in response to what it called “unjustified tariffs on Canadian steel and aluminum products.” These countermeasures are in direct response to the United States imposing tariffs on...
A New Era of Private Corporation Tax Rules – Part III
Just over a year ago, Budget 2017 announced that the Government was reviewing the taxation of private corporations. A consultation paper and draft legislation were released on July 18, 2017, which included amendments to section 120.4 of the Income Tax...
New Opportunities for Investors in the Saskatchewan Technology and Agricultural Sectors Following the Release of Saskatchewan’s 2018-2019 Provincial Budget
On April 10, 2018, Saskatchewan’s Minister of Finance, Donna Harpauer, presented Saskatchewan’s provincial budget for 2018-2019. The budget announces two new incentives for investments in the technology and agricultural sectors: 1. The Saskatchewan Technology Start-up Incentive This two-year pilot program...
CBSA’s 2018 Trade Compliance Priorities: Which Goods Are On Their Radar?
Recently, the Canada Border Services Agency (the “CBSA”) released its Trade Compliance Verification priorities for 2018. The CBSA manages trade compliance with the (i) Tariff Classification, (ii) Customs Valuation, and (iii) Origin programs. This is done by way of random...
