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Results: 1-10 of 732

Pass the Zantac: the Glaxo ruling and its effects on transfer pricing in Canada

  • Gowling Lafleur Henderson LLP
  • -
  • Canada
  • -
  • September 25 2008

On May 30th 2008, GlaxoSmithKlein Inc. (Glaxo) lost what can arguably be described as the most important transfer pricing decision in Canadian history

Tax-exempt status preserved - despite sophisticated operations

  • WeirFoulds LLP
  • -
  • Canada
  • -
  • October 20 2008

A recent Tax Court of Canada decision confirms that not-for-profit organizations can adopt the good practices, efficiencies and activities of a well-run business without jeopardizing their tax-exempt status

No redemption from the Supreme Court

  • Gowling Lafleur Henderson LLP
  • -
  • Canada
  • -
  • October 23 2008

On July 31, 2008, the Supreme Court of Canada ("SCC") delivered its reasons for judgment in Redeemer Foundation v. Canada (National Revenue)("Redeemer"

Characterization of foreign exchange losses on debt repayments: Saskferco Products ULC v. The Queen

  • McCarthy Tétrault LLP
  • -
  • Canada
  • -
  • November 18 2008

Effective January 1, 2008, the Income Tax Act (the Act) was amended to eliminate non-resident withholding tax on most arm's-length interest payments, thereby facilitating cross-border loans to Canadian borrowers

Interest deductibility: uncertain in light of Lipson?

  • Gowling Lafleur Henderson LLP
  • -
  • Canada
  • -
  • December 1 2008

The Income Tax Act (Canada) distinguishes between interest paid or payable by taxpayers on account of a business venture and a personal venture

New jurisprudence on permanent establishment

  • Gowling Lafleur Henderson LLP
  • -
  • Canada
  • -
  • December 23 2008

On May 16, 2008, the Tax Court of Canada released two important decisions dealing with the concept of permanent establishment ("PE") under treaty law

The Lipson ruling: Supreme Court of Canada releases a milestone decision related to tax planning and interest deductibility

  • McCarthy Tétrault LLP
  • -
  • Canada
  • -
  • January 8 2009

Today, the Supreme Court of Canada released its decision and reasons in Lipson v Her Majesty the Queen

Lipson v. the Queen: Lipson decision creates uncertainty

  • Fasken Martineau DuMoulin LLP
  • -
  • Canada
  • -
  • January 8 2009

On January 8, 2009, the Supreme Court of Canada dismissed the taxpayer’s appeal in Lipson v. The Queen (“Lipson”

Lipson’s "spousal twist" subject to GAAR

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • January 13 2009

On January 8, 2009, a majority of the Supreme Court of Canada (4:3) dismissed the taxpayer’s appeal in Lipson v. The Queen. The facts in Lipson were similar to the facts of the Singleton case (which was decided by the Supreme Court in favour of the taxpayer); however, Lipson involved the transfer of company shares between spouses financed with borrowed funds secured against the taxpayer’s residence which triggered the application of the spousal attribution rules

Lipson: Supreme Court hands CRA biggest-ever GAAR victory in a cliff-hanger

  • Dentons
  • -
  • Canada
  • -
  • January 8 2009

A badly fractured seven-member panel of the Supreme Court of Canada gave the Canada Revenue Agency its biggest-ever GAAR victory in Lipson v. The Queen