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Employer-provided parking: when is it a taxable benefit to the employee?

Borden Ladner Gervais LLP
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Canada
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October 1 2012

Employee compensation may include not only salary and wages but also non-cash compensation such as stock options and non-monetary benefits such as supplemental health and life insurance

Barbados spousal trust strategy fails Canadian trust and GAAR tests

Borden Ladner Gervais LLP
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Canada
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October 7 2009

In Paul Antle and Renee Marquis-Antle Spousal Trust v. The Queen, the Tax Court considered a series of transactions implemented by a Canadian resident taxpayer known as a “capital property step-up strategy”

Crown appeals General Electric case

Borden Ladner Gervais LLP
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Canada
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March 18 2010

On January 4, 2010, the Crown deposited with the Federal Court of Appeal its notice of appeal of the Tax Court of Canada's judgment in the case of General Electric Capital Canada Inc

Tax court finds unanimous shareholders’ agreement affected legal control of a corporation its non-resident shareholders

Borden Ladner Gervais LLP
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Canada
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June 5 2012

Determining who controls a corporation is relevant to determining the availability of certain tax benefits provided by the Income Tax Act (Canada

Employee stock option surrender payments non-deductible

Borden Ladner Gervais LLP
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Canada
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February 11 2011

On December 21, 2010, the Tax Court of Canada dismissed the taxpayer’s appeal in Imperial Tobacco Canada Limited v. The Queen

Central management and control determines trust residence

Borden Ladner Gervais LLP
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Canada
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September 23 2009

In Garron, M. et al. v. The Queen, the Tax Court of Canada considered whether two Barbados trusts (the “Trusts”) were entitled to claim the benefit of the capital gains exemption in Article XIV(4) of the Canada-Barbados Income Tax Convention (the “Treaty”) on their dispositions to an arm’s length purchaser of shares of two Canadian holding corporations which indirectly owned a Canadian automotive parts manufacturing and assembly business

Arm’s length principle interpreted by Canadian court

Borden Ladner Gervais LLP
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Canada
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December 8 2009

On December 4, 2009, the long awaited decision in General Electric Capital Canada Inc. v. The Queen was released by Canada's Tax Court

Money lender’s doubtful and bad debt claims on “extraordinary” loan disallowed

Borden Ladner Gervais LLP
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Canada
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November 30 2009

In Heron Bay Investments Ltd. v. The Queen, the Tax Court considered whether a $3.77 million non-recourse demand loan made in 1994 by Heron Bay to another corporate group member met the criteria for deductibility under the Income Tax Act (Canada) as either a doubtful debt or a bad debt in Heron Bay’s 1995 taxation year

Canada’s Supreme Court to hear GAAR appeal

Borden Ladner Gervais LLP
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Canada
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February 9 2010

The concept of paid-up capital is important for Canadian tax purposes in that, unlike certain of its treaty partners, Canada permits corporations to return capital to shareholders (even if they have accumulated earnings and profits for tax purposes), without payment of Canadian non-resident withholding tax

Stripped interest coupon planning not subject to GAAR

Borden Ladner Gervais LLP
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Canada
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May 19 2010

On May 17, 2010, the Federal Court of Appeal allowed the taxpayer’s appeal in Lehigh Cement Limited v. The Queen, holding that the general anti-avoidance rule (“GAAR”) did not apply to a series of transactions through which Lehigh’s interest payments on debt held by a related non-resident corporation were paid free of withholding tax to an arm’s length non-resident bank

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