( Disponible en anglais seulement )
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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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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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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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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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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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...
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The 2010 Ontario Budget was announced on March 25, 2010, and on May 18, 2010, Bill 16, Creating the Foundation for Jobs and Growth Act, 2010, the legislation enacting many of the changes announced in the Budget, received both its...
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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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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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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...
