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Canada - March 27 2013
Budget 2013 proposes a number of changes to the provisions of the Income Tax Act (Canada) (the "Tax Act") governing the taxation of individuals…
Canada - March 27 2013
Budget 2013 proposed a number of GST/HST and customs changes, including changes to (i) relieve the GST/HST compliance burden for employers who…
Canada - October 24 2012
Earlier this year in Toronto-Dominion Bank v Canada ("TD"), the Supreme Court of Canada (the "SCC") provided much needed guidance regarding the validity of a requirement to pay (or notice of garnishment) (a "Requirement"), which was issued to the Toronto-Dominion Bank (the "TD Bank") on behalf of the federal Minister of National of Revenue (the "Minister") under subsections 317(1) and (3) of the Excise Tax Act (the "ETA") to recover moneys owed by a tax debtor, but which was neither settled nor executed, before the tax debtor entered into bankruptcy.
Canada - June 22 2012
In a recent letter (the "Finance Letter") to the Joint Committee of the Canadian Bar Association and the Canadian Institute of Chartered Accountants (the "Joint Committee"), the Department of Finance (Canada) ("Finance") announced its intention to recommend a number of technical amendments to the "prohibited investment" rules (the "PI Rules") in the Income Tax Act (Canada) that govern investments made by registered retirement savings plans ("RRSPs"), registered retirement income funds ("RRIFs") and tax-free savings accounts ("TFSAs", and collectively with RRSPs and RRIFs, "Plans").
Canada - March 31 2012
Canada has enacted a detailed set of statutory provisions, commonly referred to as the "thin capitalization" rules, that restrict the deductibility of interest payments made to certain connected, non-resident lenders.
