June 2012 Copthorne Decision: Supreme Court of Canada unanimously applies GAAR Canada Revenue Agency Eliminates Tax Deferral for Joint Ventures Transalta Case: FCA Adopts Residual Approach to Valuation of GoodwillMore from this issue
December 2011 CRA Guidance on Whether Canadian Captive Service Subsidiary Constitutes PE of Foreign Parent Court Upholds Capital Loss Recognition on Exercise of Exchangeable Share Rights Employee Profit Sharing Plans – Changes to Come?More from this issue
June 2011 Cross-Border and International Tax: New Canadian Compliance Requirements for Non-Residents of Canada 2011 Federal Budget – Focus on Anti-Avoidance Rules Miller Thomson’s National M&A Work is Ranked Top Tier Among Canadian Law Firms and GloballyMore from this issue
October 5, 2010 Current Cases: Sale Of Business – Defining Goodwill And Defending The Purchase Price Allocation Cross-Border Tax: Canada-US Tax Treaty Update – CRA Views On Treaty Entitlement On Canadian Source Income And Profit For US LLC Shareholders Canadian Tax: Update On Restrictive Covenant ProposalsMore from this issue
July 2010 The Miller Thomson Foundation: Sixteen Years as a Proud Supporter of Post-Secondary Education in Canada Cross-Border Tax: Canada-US Tax Treaty Update: CRA Views on Treaty Benefits on Dividends Paid by Canadian ULC’s International Tax: Recent Changes to “taxable Canadian property” Regime for Purchasers and Non-resident Vendors of TCPMore from this issue
March 2010 Cross-Border Tax: Canada-US Tax Treaty Update: Canada Revenue Agency Views on Solutions for Interest and Other Payments from Canadian Unlimited Liability Companies Cross-Border Tax: Canadian Multinationals Allowed to Double-Dip Current Cases: General Electric Case: Deductibility of Guarantee FeesMore from this issue
Winter 2007 Canadian Renewable & Conservation Expense (“CRCE”) “Green” Energy Tax Incentives GST Section 167 Income Trusts: A New Tax Regime for Publicly – Listed Flow -Through EntitiesMore from this issue
November 2007 Personal Services Corporations: Part II – A Review of Recent Cases GST Section 156 Election: Closely Related Parties Le Langage Legislatif en Matiere Fiscale et Ce Qu’en Pensent nos TribunauxMore from this issue
Fall 2007 New Canada – U.S. Tax Convention Protocol: Mandatory Arbitration Pensions and Other Registered Plans Stock OptionsMore from this issue
Spring 2007 Budget 2007 – Summary of International Tax Measures Elimination of Separate Québec Elections CRA Loses Employment Profit Sharing Plan Case – Part 1More from this issue
