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Results: 1-10 of 128

Plan Nord Québec’s new mining royalty regime

  • Osler, Hoskin & Harcourt LLP
  • -
  • Canada
  • -
  • May 9 2013

On May 6, 2013, the Québec government revealed its long-awaited mining royalty and tax regime in an official document titled “A New Mining Tax

President Obama’s pension cap: who would really be affected?

  • Osler, Hoskin & Harcourt LLP
  • -
  • Canada
  • -
  • May 7 2013

The President's recent budget proposal would impose a new cap on tax-favored retirement benefits. Annual contributions and accruals under tax-favored

Budget briefing 2013

  • Osler, Hoskin & Harcourt LLP
  • -
  • Canada
  • -
  • March 21 2013

The Honourable Jim Flaherty, Minister of Finance, tabled Budget 2013 today. In his Budget Speech, the Minister lauded Canada's economic strength and

Loans to U.S. borrowers - deemed dividend problem with credit support from non-U.S. subsidiaries

  • Osler, Hoskin & Harcourt LLP
  • -
  • Canada
  • -
  • October 4 2011

When non-U.S. subsidiaries of a U.S. borrower provide credit support for loans made to their U.S. parent, unexpected and often significant U.S. tax costs can result

Technical explanation clarifies Protocol to Canada-U.S. Tax Treaty

  • Osler, Hoskin & Harcourt LLP
  • -
  • Canada, USA
  • -
  • July 11 2008

On July 10, 2008 the U.S. Treasury Department released the Technical Explanation (the TE) to the September 21, 2007 protocol (the Protocol) to the Canada-U.S. Income Tax Convention (the Treaty) and the Canadian Department of Finance issued a press release indicating its agreement with the TE

New U.S. foreign tax credit limitation applies to acquisitions of Canadian companies

  • Osler, Hoskin & Harcourt LLP
  • -
  • Canada, USA
  • -
  • February 2 2011

Effective January 1, 2011, new U.S. legislation limits the foreign tax credits available to a U.S. corporation that directly or indirectly acquires a Canadian corporation in certain basis step-up acquisitions

Taxpayer wins “beneficial ownership” case: Velcro Canada Inc. v. The Queen

  • Osler, Hoskin & Harcourt LLP
  • -
  • Canada
  • -
  • February 28 2012

The Tax Court of Canada recently allowed the taxpayer’s appeal in Velcro Canada Inc. v. The Queen

Canada Revenue Agency says supplemental employee retirement plans could be salary deferral arrangements

  • Osler, Hoskin & Harcourt LLP
  • -
  • Canada
  • -
  • June 18 2007

The Canada Revenue Agency (CRA) has recently confirmed its position that a supplemental employee retirement plan (SERP) may be subject to the “salary deferral arrangement” (SDA) rules in Canada’s Income Tax Act (ITA) if it provides “unreasonable” superannuation or pension benefits

Quebec moves ahead with pooled registered pension plans

  • Osler, Hoskin & Harcourt LLP
  • -
  • Canada
  • -
  • March 18 2011

Only one day has passed since the Quebec Finance Minister Raymond Bachand delivered the 2010-2011 budget speech and much has already been said in the media about Quebec's proposal to implement "Voluntary retirement savings plans" (VRSPs

Introduction to Canada’s taxation system

  • Osler, Hoskin & Harcourt LLP
  • -
  • Canada
  • -
  • March 31 2009

Several federal and provincial tax considerations are relevant to non-residents seeking to do business in Canada