Other Measures
IN THIS SECTION: First-Time Donor’s Super Credit Expanded Collection and Enforcement Powers related to Charitable Donation Tax Shelters Extended Reassessment Period: Tax Shelters and Reportable Transactions Taxes in Dispute and Charitable Donation Tax Shelters Information Regarding Unnamed Persons Electronic Suppression...
Customs Tariff Measures
IN THIS SECTION: Tariff Relief for Canadian Consumers Modernizing Canada’s General Preferential Tariff Regime for Developing Countries Tariff Relief for Canadian Consumers The Budget proposes to eliminate customs tariffs on baby clothing, and sports and athletic equipment (excluding bicycles)...
Federal Budget 2014
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. ...
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...
A Brief Summary of the Post STEP Conference Session
It’s Personal (Preserving Wealth for People and Private Companies) Special Edition, Volume 5, Issue 3
Copthorne Decision: Supreme Court of Canada unanimously applies GAAR
In its most recent decision involving the application of the general anti-avoidance rule (the “GAAR”), under section 245 of the Income Tax Act (Canada) (the “Act”) a unanimous Supreme Court of Canada (the “SCC”) applied the GAAR to a complex...
