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Overview of Limitation on Benefits Article in Canada-U.S. Tax Treaty
The Canada-United States Tax Treaty (the “Tax Treaty”) is unique among Canada’s tax treaties in its approach to prevent “treaty shopping”. Treaty shopping generally refers to the acquisition and enjoyment of treaty benefits under a given tax treaty by persons...
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SCC Tax Cases 2012 in Review: The Death of Moldowan and the First Transfer Pricing Decision
There are only a few tax cases that make it to the Supreme Court of Canada (“SCC”). Indeed, any party that has sought leave to appeal to the SCC knows only too well that it is an exceptionally difficult task....
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Overview of New Canada-Hong Kong Tax Treaty
On November 11, 2012, the Government of Canada signed a tax treaty with the Government of the Hong Kong Special Administrative Region of the People’s Republic of China (referred to herein as “Hong Kong”) for the avoidance of double taxation...
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Canadian Tax Treatment of Mortgage Investment Corporations and Their Shareholders
A mortgage investment corporation (“MIC”) and its shareholders are entitled to special tax treatment under section 130.1 of the Income Tax Act (Canada) (the “Act”). These special rules were introduced to attract more money to the Canadian mortgage market for...
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Recent Proposed Changes to Rules Applicable to Personal Services Business
Back in the 1970s, while the Montreal Canadiens were dominating the NHL, Ken Dryden backstopped the Canadiens to win six Stanley Cups. While much can be said about Ken Dryden’s heroics in winning the Stanley Cup, this is, after all,...
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Using the Oppression Remedy to Enforce Unpaid Corporate Judgments
Tax for the Owner-Manager, Canadian Tax Foundation, April 2013
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Ease Funding Challenges with Letters of Credit
Benefits Canada, April 2013
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Federal Budget 2014
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Previously Announced Measures
The Government intends to proceed with the following previously announced tax and related measures, as modified to take into account consultations and deliberations since their release: Proposed changes to certain GST/HST rules relating to financial institutions released on January 28,...
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Introduction
Minister of Finance Jim Flaherty today tabled the 2013 Federal Budget (the “Budget”) entitled Jobs, Growth and Long-Term Prosperity – Economic Action Plan 2013. We are pleased to provide our summary of tax measures contained in the Budget. The Budget...
