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BCCA finds limited partners not purchasers of property sold to limited partnership

McCarthy Tétrault LLP
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Canada
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February 27 2013

When a limited partner sells property to the limited partnership, is the limited partner itself a purchaser of that property, or is the only

Denial of Canadian R&D tax credits not a CCPC based on de facto control

Norton Rose Canada LLP
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Canada
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February 22 2013

Under subsection 127(10.1) of the Income Tax Act (the Act), a Canadian-controlled private corporation (CCPC) may benefit from an additional 15

BLG Monthly Update

Borden Ladner Gervais LLP
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Argentina, Australia, Canada, United Kingdom, USA
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December 19 2012

The BLG Monthly Update is a digest of recent developments in the law which Neil Guthrie, our National Director of Research, thinks you will find

TCC finds that shares were validly issued; minute books could be corrected

Thorsteinssons LLP
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Canada
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September 10 2012

In Twomey v. The Queen (2012 TCC 310), the sole issue was whether shares were “issued” to the taxpayer in 1995, and not in 2005

Science fiction: Bagtech on CCPC status and USAs

Davies Ward Phillips & Vineberg LLP
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Canada
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August 22 2012

In Bioartificial Gel Technologies Inc. c. La Reine (2012 CCI 120) (Bagtech), the TCC found that a unanimous shareholders' agreement (USA) caused a corporation to qualify as a CCPC, and thus to be eligible for the refundable SR & ED tax credit, even though more than 50 percent of the voting shares of the corporation were held by nonresidents

Unanimous shareholders' agreement affects company's legal control

Borden Ladner Gervais LLP
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Canada
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June 29 2012

The Tax Court recently held that a company qualified as a Canadian-controlled private corporation

Doing business and raising capital in Canada

Torys LLP
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Canada
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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

Tax court rules against CRA policy on shareholder control of CCPC

Gowling Lafleur Henderson LLP
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Canada
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June 15 2012

In a decision released on April 12, 2012, the Tax Court of Canada (“Court”) concluded that even if 70 of the voting shares of a corporation were owned by non-residents, de jure control could still be held by Canadian residents and the corporation could maintain its status as a Canadian-controlled private corporation (“CCPC”

Supreme Court of Canada declines to hear an appeal on whether an expenditure in the course of a corporate reorganization was on capital or income account

Dentons
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Canada
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May 24 2012

Earlier today, the Supreme Court of Canada (The Chief Justice, Justice Rothstein and Justice Moldaver) dismissed an application for leave to appeal by Imperial Tobacco dealing with the classic distinction between deductible corporate expenditures on income account and non-deductible corporate expenditures on capital account

FCA affirms the importance of GAAP in computing liability for LCT rejecting the Crown’s economic substance argument

Dentons
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Canada
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May 8 2012

The Federal Court of Appeal has once again affirmed the importance of Generally Accepted Account Principles (GAAP) in computing liability for the large corporation tax (LCT) applicable prior to 2006 while rejecting the Crown’s economic substance argument: The Queen v. Bombardier Inc

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Search results

BCCA finds limited partners not purchasers of property sold to limited partnership

Denial of Canadian R&D tax credits not a CCPC based on de facto control

BLG Monthly Update

TCC finds that shares were validly issued; minute books could be corrected

Science fiction: Bagtech on CCPC status and USAs

Unanimous shareholders' agreement affects company's legal control

Doing business and raising capital in Canada

Tax court rules against CRA policy on shareholder control of CCPC

Supreme Court of Canada declines to hear an appeal on whether an expenditure in the course of a corporate reorganization was on capital or income account

FCA affirms the importance of GAAP in computing liability for LCT rejecting the Crown’s economic substance argument

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