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Economic action plan 2013 closing more tax planning opportunities

McCarthy Tétrault LLP
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Canada
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March 22 2013

On Thursday, March 21, 2013 (Budget Day), the Honourable Jim Flaherty, Minister of Finance, delivered his eighth federal budget (Budget 2013

Budget 2012 legislation more revisions to foreign affiliate "dumping" and shareholders loan rules

McCarthy Tétrault LLP
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Canada
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November 16 2012

On October 15, 2012, the Minister of Finance (Canada) tabled a Notice of Ways and Means Motion (NWMM) in the House of Commons to implement certain measures from the March 29, 2012 Federal budget (Budget 2012) that were amended in draft legislation released on August 14, 2012 (August Proposals

Minister of Finance (Canada) releases revised budget proposals

McCarthy Tétrault LLP
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Canada
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September 19 2012

The March 29, 2012 federal budget proposed amendments to a number of international tax measures contained in the Income Tax Act (Canada

Foreign affiliate proposals some welcome and unwelcome changes

McCarthy Tétrault LLP
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Canada
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September 12 2011

On August 19, 2011, the Department of Finance (Finance) released extensive proposed amendments (2011 Proposals) to the foreign affiliate rules which, in some cases, replace a number of the more controversial amendments that were contained in the proposed amendments released on February 27, 2004 (2004 Proposals) and that may be viewed as a significant shift in tax policy

Coupon strips: an easy avoidance of withholding tax no more

McCarthy Tétrault LLP
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Canada
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May 2 2011

In Lehigh Cement Limited v. The Queen, 2010 DTC 2081 (FCA) (Lehigh), the Federal Court of Appeal considered the application of the general anti-avoidance rule (GAAR) contained in section 245 of the Income Tax Act (Canada) (Act) to a coupon stripping transaction used to avoid withholding tax on interest under the former 525 rule contained in subsection 212(1)(b) of the Act

"Earnings" and single-member LLCs: where do we start?

McCarthy Tétrault LLP
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Canada
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March 8 2011

Regulations to the Income Tax Act (Canada) (Act) contain rules with respect to the computation of the earnings of a foreign affiliate of a Canadian-resident taxpayer, which is relevant in calculating the surplus accounts of the foreign affiliate

How the CRA’s new assessing position can reduce your FAPI

McCarthy Tétrault LLP
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Canada
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September 30 2009

The Income Tax Act (Canada) contains a foreign accrual property income (FAPI) regime that imputes "passive income" earned by a non-resident corporation (a controlled foreign affiliate) to its Canadian-resident controlling shareholders on an annual accrual basis, whether or not such income is distributed to the non-resident corporation’s shareholders