Canadian individuals are well aware of the April 30 tax filing deadline for Canadian income tax returns. However, many Canadians may not be aware of the earlier April tax filing deadline of April 15 for United States tax purposes. A...
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...
CRA has announced that it is withdrawing its administrative position allowing participants in a joint venture (“JV”) to establish a fiscal period for the JV that differs from the fiscal periods of the JV participants. This change was made inevitable...
In Transalta v. The Queen, 212 FCA 20 (“Transalta”), the Federal Court of Appeal (“FCA”) confirmed that a residual approach should be applied in the valuation of goodwill in the context of an asset purchase transaction. The two-step residual approach...
Transferring employees between members of a corporate group can be an effective way to leverage expertise, promote existing corporate culture, transition business units and develop new markets. To ensure that the benefits are realized, it is important that an employee transfer...
