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International Tax: Tax Information Exchange Agreements – Overview And Update
Most international tax treaties entered into by Canada include a tax information exchange provision (e.g., Article XXVII of the Canada-US Tax Treaty) that enables the Canada Revenue Agency (“CRA”) to obtain pertinent tax information about a particular taxpayer from a...
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New Charity Tax Specific Graduate Degree
Osgoode Hall Law School at York University has launched a new part time Master of Laws (LL.M.) degree specializing in Charities and Not-for-Profit Tax Law. This degree, which we believe to be the first law degree of its kind anywhere...
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Provincial Tax: Introduction of HST – B.C. Transitional Rules
Effective July 1, 2010, a Harmonized Sales Tax (HST) will apply to payments for the supply of goods and services in British Columbia at a rate of 12% (5% federal component and 7% provincial component). On April 29, 2010, the...
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The Miller Thomson Foundation: Sixteen Years as a Proud Supporter of Post-Secondary Education in Canada
Since its formation in 1995, The Miller Thomson Foundation has awarded scholarships totalling $2,550,000 to 2,550 promising students pursuing post-secondary education in Canada. Gerald Courage, Chair of Miller Thomson LLP, along with Gary G. Campbell, Q.C. and The Rt. Hon....
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Cross-Border Tax: Canada-US Tax Treaty Update: CRA Views on Treaty Benefits on Dividends Paid by Canadian ULC’s
Treaty benefits will generally be denied under the new anti-hybrid rule under Article IV(7)(b) of the Canada-US Tax Treaty (the “Treaty”) in respect of any dividends paid on or after January 1, 2010 by Canadian unlimited liability corporations (“Canadian ULCs”)....
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International Tax: Recent Changes to « taxable Canadian property » Regime for Purchasers and Non-resident Vendors of TCP
Changes introduced by the 2010 Federal Budget will impact the obligations imposed on non-resident vendors of “taxable Canadian property” (“TCP”), such as real property situated in Canada and shares of Canadian private and public corporations, and purchasers of such properties...
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Harmonized Sales Tax (HST): The New HST and the Place of Supply Rules
Just when you thought you were safe to purchase services from an Alberta lawyer or consultant, the new “Place of Supply Rules” were recently announced by the Department of Finance. These are Federal rules, but apply to all HST participating...
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Canadian Tax: Recent Changes to the Employee Stock Options Rules
Overview Generally, pursuant to subsection 7(1) of the Income Tax Act (Canada) (the « Act ») where an employer has agreed to sell securities of its capital stock to an employee, the employee is deemed to have received a taxable benefit from...
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Current Cases: The Propep Decision: The Associated Corporation Rules
In The Queen v. Propep Inc. (2009 FCA 274), the Federal Court of Appeal (“FCA”) was asked to determine whether Propep Inc. (“Propep”) was associated with two other corporations, and therefore required to share the small business deduction. The FCA...
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2010-2011 Quebec Budget Highlights
Having faired relatively well in comparison to the other provinces in the latest recession, Québec is facing greater challenges on the long-term horizon. In fact, the gross provincial debt is expected to reach 53.2% of the gross domestic product, making...
