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Cross-Border Tax: Canada-US Tax Treaty Update – CRA Views On Treaty Entitlement On Canadian Source Income And Profit For US LLC Shareholders
The Canada Revenue Agency (“CRA”) recently confirmed that it continues to maintain its long-standing position that a US limited liability company (“US LLC”) that is treated as a fiscally transparent entity for US tax purposes is not entitled to treaty...
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Canadian Tax: Update On Restrictive Covenant Proposals
On July 16, 2010, the Canadian federal government released further amendments to the draft legislation dealing with payments for non-competition and other restrictive covenants. These proposals continue to be significant for taxpayers who acquire or dispose of businesses. A Colourful...
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International Tax: The Lehigh Cement Case – Canadian Non-Resident Withholding Tax On Interest Payments
On May 17, 2010, the Federal Court of Appeal (“FCA”) rendered its judgment in Lehigh Cement Limited v. R., 2010 FCA 124 (“Lehigh”), in which it found that the transaction in issue entered into by the corporate taxpayer, Lehigh Cement...
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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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2010-2011 British Columbia Budget Highlights
On March 2, 2010, the B.C. Budget entitled “Building a Prosperous British Columbia” was tabled. The Budget is targeted at enhancing vital public services, refocusing government spending to eliminate the deficit, and providing a range of initiatives to stimulate economic...
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2010-2011 Alberta Budget Highlights
In its 2010-11 Budget, introduced in the Legislature on February 9, 2010, the Alberta Conservative government has sought to strike a balance between deficit reduction, and continuation of program and planned capital spending. Reiterating its intention to return Alberta to...
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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”)....
