Search results

Order by most recent / most popular / relevance

Results: 1-10 of 18

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

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

Dentons
-
Canada
-
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

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

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

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
-
Canada
-
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
-
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

'Break fee': capital or revenue?

DLA Cliffe Dekker Hofmeyr
-
Canada
-
November 30 2012

A break fee is a fee paid by a target company to bidders, during an acquisition, if the pending deal is terminated

A corporate divorce alternative when the butterfly won't fly

Gowling Lafleur Henderson LLP
-
Canada
-
October 20 2010

Sometimes, two is better than one

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

Foreign spin off transactions and dividend in kind - conflicting rulings that reinforce an earlier precedent

Gowling Lafleur Henderson LLP
-
Canada
-
September 15 2011

On June 29, 2007, Tyco International Ltd. (“Tyco”) underwent a corporate reorganization that involved spinning off Tyco Electronics Ltd. (“Electronics”) and Covidien Ltd. (“Covidien”), and a stock consolidation

next >

Search results

SCC denies leave to appeal in break fee case

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

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

'Break fee': capital or revenue?

A corporate divorce alternative when the butterfly won't fly

Doing business and raising capital in Canada

Foreign spin off transactions and dividend in kind - conflicting rulings that reinforce an earlier precedent

Current Search

Suggested Facets

Author

Firm Name

Jurisdiction

Workarea