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Transactions to minimize the tax implications of the twenty-one-year rule for trusts

Fasken Martineau DuMoulin LLP
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Canada
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April 30 2013

For income tax purposes, trusts are generally deemed to dispose of their capital property every 21 years following their creation, resulting in the

SCC denies leave to appeal in break fee case

Thorsteinssons LLP
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Canada
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May 6 2013

In Morguard Corporation v. The Queen, the Federal Court of Appeal (FCA) upheld a Tax Court decision that a "break fee" received by a parent company

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

Tower financing deduction denied by Tax Court of Canada: FLSMIDTH Ltd. v. The Queen

Dentons
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Canada
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January 13 2012

Taxpayers that have implemented crossborder tower financing structures and that have claimed a Canadian tax deduction for any U.S. taxes paid should revisit their structures carefully in light of the Tax Court of Canada’s recent decision in FLSMIDTH Ltd., v. The Queen (2012 TCC 3), which is the Court’s first decision concerning tower structures

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

Osler, Hoskin & Harcourt LLP
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Canada, USA
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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 loses “break fee” appeal

Thorsteinssons LLP
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Canada
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December 2 2012

In Morguard Corporation v. The Queen, the Federal Court of Appeal (FCA) upheld the Tax Court of Canada decision that a “break fee” received on an attempted acquisition of a target company was ordinary income to the recipient

Supreme Court of Canada grants leave in tax case involving contingent liabilities

Cassels Brock & Blackwell LLP
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Canada
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July 4 2012

In a rare oral hearing, the Supreme Court of Canada granted leave in the case of Daishowa-Marubeni International Ltd. v. The Queen

Imperial Tobacco redux an unwelcomed revisit to the deductibility of payments to option holders for surrendering stock options in the context of corporate reorganizations and acquisitions

Gowling Lafleur Henderson LLP
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Canada
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February 28 2011

Canada Revenue Agency ("CRA") generally permits the deduction of payments made by an employer to employees who surrender their options under an employee stock option plan ("ESOP") in the ordinary course of business

TCC rules on taxation of break fees

McMillan LLP
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Canada
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July 31 2012

In the recent decision Morguard Corp. v R., 2012 TCC 55, the Tax Court of Canada ("TCC") considered the proper tax treatment of a break fee in the hands of a recipient as a result of a failed takeover bid

U.S. and multi-national companies engaged in Canadian business operations through controlled Canadian subsidiaries need to stand on guard for possible legislation on interest stripping and other rules

Fox Rothschild LLP
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Canada, USA
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December 6 2012

Many U.S. companies engage in business operations in foreign countries, including Canada, through the use of a controlled or wholly owned subsidiary

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Search results

Transactions to minimize the tax implications of the twenty-one-year rule for trusts

SCC denies leave to appeal in break fee case

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

Tower financing deduction denied by Tax Court of Canada: FLSMIDTH Ltd. v. The Queen

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

Taxpayer loses “break fee” appeal

Supreme Court of Canada grants leave in tax case involving contingent liabilities

Imperial Tobacco redux an unwelcomed revisit to the deductibility of payments to option holders for surrendering stock options in the context of corporate reorganizations and acquisitions

TCC rules on taxation of break fees

U.S. and multi-national companies engaged in Canadian business operations through controlled Canadian subsidiaries need to stand on guard for possible legislation on interest stripping and other rules

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