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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...
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Personal Income Tax Measures
IN THIS SECTION: Synthetic Dispositions Character Conversion Transactions Trust Loss Trading Non-Resident Trusts Consultation on Graduated Rate Taxation of Trusts and Estates Registered Pension Plans: Correcting Contribution Errors Labour-Sponsored Venture Capital Corporations Tax Credit Lifetime Capital Gains Exemption Dividend Tax...
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Business Income Tax Measures
IN THIS SECTION: Leveraged Life Insurance Arrangements Corporate Loss Trading Taxation of Corporate Groups Mining Expenses Restricted Farm Losses Reserve for Future Services Additional Deduction for Credit Unions Manufacturing and Processing Machinery and Equipment: Accelerated Capital Cost Allowance Clean Energy...
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International Taxation
IN THIS SECTION: International Tax Evasion and Aggressive Tax Avoidance Improvements to Foreign Reporting Requirements: Form T1135 Thin Capitalization Rules Treaty Shopping International Banking Centres International Tax Evasion and Aggressive Tax Avoidance High on the priority list of the...
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Sales and Excise Tax Measures
IN THIS SECTION: GST/HST and Health Care Services GST/HST Pension Plan Rules GST/HST Business Information Requirement GST/HST on Paid Parking GST/HST Treatment of the Governor General Excise Duty Rate on Manufactured Tobacco GST/HST and Health Care Services Home Care...
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Tax Evasion: The Clock Continues to Tick and the Hourglass Runs to Empty
It's Personal (Preserving Wealth for People and Private Companies)
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Transfer Pricing – The Last Word in Canada
Financier Worldwide Magazine, December edition
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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...
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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...
