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Canadian government pushes ahead with proposed tax rules in spite of pitfalls

Davies Ward Phillips & Vineberg LLP
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Canada
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October 16 2012

On October 15, 2012, the Canadian Minister of Finance tabled in the House of Commons a Notice of Ways and Means Motion to implement proposed tax changes first announced in the March 29, 2012 federal budget and included in draft legislation released on August 14, 2012

Respecting the dualistic nature of Canada’s two transfer pricing rules: a tax policy and legal analysis

Davies Ward Phillips & Vineberg LLP
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Canada
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September 18 2012

The Canadian Income Tax Act’s transfer pricing regime is a dualistic one

New IRS compliance procedure for non-resident non-filers

Davies Ward Phillips & Vineberg LLP
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Canada
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September 14 2012

The IRS has announced new streamlined procedures for U.S. citizens who are resident in Canada or other countries and who have failed to file U.S. federal income tax returns or Reports of Foreign Bank Accounts (FBARs

Canadian proposals threaten foreign controlled Canadian companies

Davies Ward Phillips & Vineberg LLP
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Canada
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September 7 2012

The recent Canadian Budget included a proposal to legislate against ‘‘foreign affiliate dumping’’, purported to be a means by which foreign-controlled Canadian companies reduce tax liability by either taking on debt or using surplus cash to acquire shares of non-Canadian members of the foreign-based group

Science fiction: Bagtech on CCPC status and USAs

Davies Ward Phillips & Vineberg LLP
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Canada
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August 22 2012

In Bioartificial Gel Technologies Inc. c. La Reine (2012 CCI 120) (Bagtech), the TCC found that a unanimous shareholders' agreement (USA) caused a corporation to qualify as a CCPC, and thus to be eligible for the refundable SR & ED tax credit, even though more than 50 percent of the voting shares of the corporation were held by nonresidents

Anti-inversion regulations severely limit substantial business activities exception, as illustrated with Canada

Davies Ward Phillips & Vineberg LLP
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Canada, USA
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August 10 2012

In 2004, Congress enacted 7874 to put an end to certain perceived abuses associated with ‘‘inversion transactions,’’ i.e., transactions in which a U.S.-based multinational corporation migrates to a lower-tax jurisdiction in order to reduce U.S. taxation

Search results

Canadian government pushes ahead with proposed tax rules in spite of pitfalls

Respecting the dualistic nature of Canada’s two transfer pricing rules: a tax policy and legal analysis

New IRS compliance procedure for non-resident non-filers

Canadian proposals threaten foreign controlled Canadian companies

Science fiction: Bagtech on CCPC status and USAs

Anti-inversion regulations severely limit substantial business activities exception, as illustrated with Canada

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