November 2014 Administrative Changes to Canada Revenue Agency’s Voluntary Disclosure Program Surplus Stripping Limits ClarifiedMore from this issue
July 2014 Rectification: Current Developments Regarding This Useful Judicial Remedy “Half-loaf” Gone Wrong: Gervais, G. et al. v. The Queen (“Gervais”). Current Changes to Testamentary Trusts and Continuing AdvantagesMore from this issue
May 2014 Canadian Federal Court of Appeal Finds Anti-Avoidance Rule Applicable to Foreign Affiliates Has Limited ScopeMore from this issue
April 2014 OECD Base Erosion and Profit Shifting (“BEPS”) Action Plan: Action 1 – Addressing Tax Challenges of Digital EconomyMore from this issue
December 2013 Supreme Court of Canada Considers Tax Regime and Common Law Principles Applicable to Statutory AmalgamationsMore from this issue
August 2013 TCC Upholds Tax Benefits of Cross-Border Refinancing Involving Foreign Affiliates SCC Daishowa Decision: Assumed Liabilities Not Considered Proceeds of Disposition Base Erosion, Profit Shifting and Tightening the Tax Noose on Multi-National EnterprisesMore from this issue
April 2013 Canadian Renewable & Conservation Expense “Green” Energy Tax Incentives Overview of Limitation on Benefits Article in Canada-U.S. Tax Treaty SCC Tax Cases 2012 in Review: The Death of Moldowan and the First Transfer Pricing DecisionMore from this issue
November 2012 Tax Treatment of Break Fees From Recipient’s Perspective Beneficial Ownership Test For Tax Treaty Benefit Entitlement CCPC Status Preserved Through Unanimous Shareholders’ AgreementMore from this issue
