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Canada’s 2010 Budget international tax changes

  • Baker & McKenzie
  • -
  • Canada
  • -
  • March 12 2010

Foreign investors, particularly private equity funds, have expressed frustration with the complexity of the reporting requirements under section 116 of the Canadian Income Tax Act (the Act) with respect to the disposition of investments in taxable Canadian property (TCP) such as shares of Canadian companies that are not listed on a stock exchange

Canadian changes to taxation of stock options

  • Baker & McKenzie
  • -
  • Canada
  • -
  • March 12 2010

An employee who exercises a stock option is generally required to include in employment income a taxable benefit equal to the difference between the fair market value of the shares on the date of acquisition and the exercise price paid by the employee

Tax Court of Canada issues ruling on GE Capital Canada guarantee fee

  • Baker & McKenzie
  • -
  • Canada
  • -
  • January 8 2010

On December 4, 2009 the Tax Court of Canada released its decision in GE Capital Canada Inc. v. Her Majesty the Queen

New related party transaction reporting requirements in Canada

  • Baker & McKenzie
  • -
  • Canada
  • -
  • May 21 2009

On December 22, 2008 the Canada Revenue Agency ("CRA") released a new version of the information reporting form T106 that includes significantly expanded levels of detail for disclosures of related party transactions