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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...
