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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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Canadian Renewable & Conservation Expense “Green” Energy Tax Incentives
This article is an overview of the Canadian income tax considerations relevant to Canadian renewable and conservation expenses (« CRCE ») initially introduced in the March 1996 Canadian Federal Budget as a new category of deductible expenses and related recent amendments included...
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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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Other Measures
IN THIS SECTION: First-Time Donor’s Super Credit Expanded Collection and Enforcement Powers related to Charitable Donation Tax Shelters Extended Reassessment Period: Tax Shelters and Reportable Transactions Taxes in Dispute and Charitable Donation Tax Shelters Information Regarding Unnamed Persons Electronic Suppression...
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Customs Tariff Measures
IN THIS SECTION: Tariff Relief for Canadian Consumers Modernizing Canada’s General Preferential Tariff Regime for Developing Countries Tariff Relief for Canadian Consumers The Budget proposes to eliminate customs tariffs on baby clothing, and sports and athletic equipment (excluding bicycles)...
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