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Results: 1-10 of 69

CRA confirms that a two-partnership structure would not constitute a tiered partnership

  • Thorsteinssons LLP
  • -
  • Canada
  • -
  • October 6 2014

In 2014-0528001E5, the CRA was asked to consider a situation where an existing partnership (Partnership A), having an off-calendar fiscal year end

CRA confirms trap on rollover of foreign affiliate shares held through a partnership

  • Thorsteinssons LLP
  • -
  • Canada
  • -
  • July 2 2014

When a Canadian company (Canco) receives a pre-acquisition surplus dividend (Pre-Acq Dividend) from a foreign affiliate (FA), s. 92(2) reduces

The CRA provides its opinion on the duties and responsibilities of an executor for the estate of a sole shareholder of a corporation

  • Thorsteinssons LLP
  • -
  • Canada
  • -
  • June 9 2014

In 2013-0513191E5, the CRA responded to four questions regarding the responsibility and liability of an executor in a situation where the deceased

Back-to-back loan proposals create tax problems

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • June 6 2014

Over-broad proposals in the federal Budget aimed at tackling 'back-to-back' loans, set to take effect in 2015, would in fact apply to a wide range of ordinary commercial transactions with no tax avoidance motive particularly where the non-resident providing security for the Canadian entity's debt is a foreign parent, sister or subsidiary of the Canadian debtor

Highlights of the February 20, 2014 Quebec budget

  • Norton Rose Fulbright LLP
  • -
  • Canada
  • -
  • February 28 2014

On February 20, 2014, the Quebec Minister of Finance and the Economy, Mr. Nicolas Marceau, tabled his government's second budget, which includes only

Taxing times

  • Bennett Jones LLP
  • -
  • Canada
  • -
  • February 20 2014

A corporation is an extremely common vehicle through which to carry on business or hold investments. There are numerous advantages and disadvantages

Taxing times: alternative routes to incorporation

  • Bennett Jones LLP
  • -
  • Canada
  • -
  • February 20 2014

While managing a real estate portfolio under a corporate structure can sometimes create tax burdens, there are other options. In part two of a

Thin cap and withholding tax rules get tougher

  • McMillan LLP
  • -
  • Canada
  • -
  • February 14 2014

In order to prevent non-residents of Canada from stripping profits from Canadian corporations in the form of deductible interest, the Income Tax Act

Using contract law to fix tax (and other) mistakes: the Supreme Court of Canada recognizes a rectification-like remedy under Quebec law

  • McCarthy Tétrault LLP
  • -
  • Canada
  • -
  • December 2 2013

A taxpayer intends to undertake a transaction on a tax-efficient basis. But the transaction gets papered wrong, and the intended tax treatment is not

Doing business in Alberta 2013

  • Davis LLP
  • -
  • Canada
  • -
  • November 30 2013

Except where otherwise noted, this paper is current as of November 2013 and provides preliminary information on Canadian and Alberta legal matters to