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Results: 1-10 of 19

“Half-loaf” gone wrong: Gervais, G. et al. v. The Queen (“Gervais”).

  • Miller Thomson LLP
  • -
  • Canada
  • -
  • July 31 2014

A recent case from the Tax Court of Canada ruled against a taxpayer who implemented a tax plan known as the "half-loaf" plan. The purpose of a

Envision: implications for Canadian corporations contemplating a merger

  • Lawson Lundell LLP
  • -
  • Canada
  • -
  • September 27 2013

On September 26, 2013 the Supreme Court released its decision in the Envision case. The case deals with the amalgamation of two credit unions, but

SCC denies leave to appeal in break fee case

  • Thorsteinssons LLP
  • -
  • Canada
  • -
  • 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

Taxpayer loses “break fee” appeal

  • Thorsteinssons LLP
  • -
  • Canada
  • -
  • 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

Federal Court of Appeal to hear argument tomorrow in “break fee” case (Morguard)

  • Dentons
  • -
  • Canada
  • -
  • November 19 2012

Tomorrow morning (November 20, 2012), the Federal Court of Appeal is scheduled to hear an appeal by Morguard Corporation (“Morguard”, formerly operating as Acktion Corporation), regarding the taxation of a “break fee” received as a result of a failed takeover bid

TCC rules on taxation of break fees

  • McMillan LLP
  • -
  • Canada
  • -
  • 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

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

  • Cassels Brock & Blackwell LLP
  • -
  • Canada
  • -
  • 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

Doing business and raising capital in Canada

  • Torys LLP
  • -
  • Canada
  • -
  • June 29 2012

We have prepared this Business Law Guide as a general overview of certain legal and business matters that may be relevant to a decision to establish or invest in a business in Canada

Transalta case: FCA adopts residual approach to valuation of goodwill

  • Miller Thomson LLP
  • -
  • Canada
  • -
  • June 13 2012

In Transalta v. The Queen, 212 FCA 20 (“Transalta”), the Federal Court of Appeal (“FCA”) confirmed that a residual approach should be applied in the valuation of goodwill in the context of an asset purchase transaction

Tax Court of Canada renders decision on taxation of break fees

  • Fasken Martineau DuMoulin LLP
  • -
  • Canada
  • -
  • May 24 2012

On February 24, 2012, the Tax Court of Canada ("TCC") rendered its decision in Morguard Corporation v. Her Majesty the Queen (2012 TCC 55 PDF) on the issue of the taxation of break fees received in the context of a takeover bid pursuant to a "lock-up agreement"