Budget 2013: deconstructing derivatives – capturing character conversion transactions *

Canada - March 27 2013
One of the "tax loopholes" targeted in Budget 2013 is a category of financial transactions dubbed "character conversion transactions" by the…

Co-authors: Michael Friedman, Peter Botz.

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Budget 2012: expansion of "prohibited investment" and "advantage" rules to retirement compensation arrangements ("RCAs") *

Canada - April 1 2012
In Budget 2012, the Government proposed to expand the "prohibited investment" and "advantage" tax regimes that were first unveiled in 2009 as the anti-avoidance control for Tax-free Savings Accounts ("TFSAs").

Co-authors: Michael Friedman, Ashley M. Palmer, Peter Botz.

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Further changes to new RRSP/RRIF anti-avoidance rules introduced *

Canada - October 14 2011
On October 4, 2011, the federal government introduced formal legislation to enact certain proposals first announced in this year's federal Budgets (the "Budget Legislation").

Co-authors: Michael Friedman, Todd A. Miller, Carl Irvine.

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Budget 2011: proposed changes target abuse of RRSPs and RRIFs *

Canada - March 25 2011
In response to concerns about the increased use of registered retirement savings plans ("RRSPs") and registered retirement income funds ("RRIFs", and collectively with RRSPs, "Registered Plans") in abusive tax-avoidance arrangements, Budget 2011 proposes a number of legislative changes to the Income Tax Act (Canada) (the "Tax Act") to strengthen and update the anti-avoidance rules applicable to such plans.

Co-authors: Michael Friedman, Ryan L. Morris.

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Shutdown of foreign tax credit generators *

Canada - March 9 2010
Budget 2010 announced proposed amendments aimed at denying the benefits potentially associated with so-called "foreign tax credit generator" schemes.

Co-authors: Michael A. Thackray, Q.C., Andrew Etcovitch.

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