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OECD Base Erosion and Profit Shifting (“BEPS”) Action Plan: Action 1 – Addressing Tax Challenges of Digital Economy
In July 2013, the Organisation for Economic Co-operation and Development (the “OECD”) released the BEPS Action Plan in response to concerns expressed by policymakers around the world that multinational enterprises (“MNEs”) were engaging in tax planning to artificially reduce taxable income...
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Previously Announced Measures
Budget 2014 confirms the Government’s intention 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 automobile expense deduction limits and the prescribed rates...
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Business Income Tax Measures
IN THIS SECTION: Remittance Thresholds for Employer Source Deductions Tax Incentives for Clean Energy Generation Consultation on Eligible Capital Property Remittance Thresholds for Employer Source Deductions Employers have an obligation to withhold amounts from remuneration paid to employees in respect...
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Personal Income Tax Measures
IN THIS SECTION: Adoption Expense Tax Credit Medical Expense Tax Credit Search and Rescue Volunteers Tax Credit Extension of the Mineral Exploration Tax Credit for Flow-Through Share Investors Farming and Fishing Businesses Tax Deferral for Farmers Amateur Athlete Trusts Pension...
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International Tax Measures
IN THIS SECTION: Captive Insurance Companies Offshore Regulated Banks Back-to-Back Loans Consultation on Tax Planning by Multinational Enterprises Consultation on Treaty Shopping Update on the Automatic Exchange of Information for Tax Purposes Update on Tax Treaties and Tax Information Exchange...
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Sales and Excise Tax Measures
IN THIS SECTION Improving the Application of the GST/HST to the Health Care Sector GST/HST Election for Closely Related Persons Joint Ventures Strengthening Compliance with GST/HST Registration Other Excise Measures Improving the Application of the GST/HST to the Health...
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Other Measures
IN THIS SECTION: Charities and Not-for-Profit Measures Aboriginal Tax Policy Charities and Not-for-Profit Measures The 2014 Budget introduced several changes and developments that are of particular relevance to registered charities, their donors and not-for-profit organizations (NPO); these include: Enhanced tax...
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Customs Tariff Measures
IN THIS SECTION Customs Tariff Treatment of the Governor General Support of Offshore Oil and Gas Development Customs Tariff Treatment of the Governor General Currently, articles imported for use by the Governor General are exempt from customs duties. The Governor...
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Introduction
Minister of Finance Jim Flaherty today tabled the 2014 Federal Budget (the “Budget”) entitled The Road to Balance: Creating Jobs and Opportunities. We are pleased to provide our summary of proposed tax measures contained in the Budget. There were no...
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Supreme Court of Canada Considers Tax Regime and Common Law Principles Applicable to Statutory Amalgamations
Envision Credit Union v. R.[1] (« Envision« ) concerned the tax consequences of an amalgamation under section 87 of the Income Tax Act (Canada) (the “Act”). Section 87 of the Act provides express rules governing the tax consequences of « qualifying » amalgamations, being...
