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The Canada-United States Tax Treaty (the “Tax Treaty”) is unique among Canada’s tax treaties in its approach to prevent “treaty shopping”. Treaty shopping generally refers to the acquisition and enjoyment of treaty benefits under a given tax treaty by persons...
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There are only a few tax cases that make it to the Supreme Court of Canada (“SCC”). Indeed, any party that has sought leave to appeal to the SCC knows only too well that it is an exceptionally difficult task....
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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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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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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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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...
