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Results: 1-10 of 83

CRA says s. 103 and s. 80 did not apply on sale of a partnership

  • Thorsteinssons LLP
  • -
  • Canada
  • -
  • February 16 2015

In 2014-0529981I7, the CRA Rulings Directorate considered a case where partnership interests and a debt obligation (Particular Note) owed by a

Increase to lifetime capital gains exemption (and other indexed amounts) for 2015

  • Thorsteinssons LLP
  • -
  • Canada
  • -
  • February 11 2015

In the 2013 Federal Budget, the government announced that the lifetime capital gains exemption (LCGE) for dispositions of qualified small business

CRA sued for $32million for threatening to intimidate taxpayers into accepting settlement

  • Thorsteinssons LLP
  • -
  • Canada
  • -
  • February 6 2015

Cardel Construction, a Calgary-based development company, recently initiated a lawsuit against the Canada Revenue Agency (the “CRA”) seeking

CRA says mid-year amalgamation did not engage partnership deferral rules

  • Thorsteinssons LLP
  • -
  • Canada
  • -
  • February 2 2015

In 2014-0539191E5, a Canadian corporation (A Co) with a December 31 taxation year end had a significant interest in a partnership (Partnership) with

Doing Business in Canada: A Legal Overview

  • Torkin Manes LLP
  • -
  • Canada
  • -
  • January 31 2015

It has been said that Canada is one of the most unique and enjoyable places in the world for a non-Canadian to explore. Here we

CRA would deny request for change to fiscal period of partnership

  • Thorsteinssons LLP
  • -
  • Canada
  • -
  • January 26 2015

In 2014-0529311E5, the CRA considered a hypothetical case where a partner was selling its partnership interest and wished to cause a fiscal year end

CRA permits amendment to DSU plan to allow payment in common shares

  • Thorsteinssons LLP
  • -
  • Canada
  • -
  • January 5 2015

In Advance Tax Ruling 2011-0418571R3 (recently released), the CRA ruled that an amendment to an existing plan established pursuant to Regulation

GSTHST joint-venture elections and nominee corporations

  • Bennett Jones LLP
  • -
  • Canada
  • -
  • December 19 2014

Joint-ventures (JVs) with nominee corporations or bare trustees that have been elected to account for the GSTHST of the JV should be aware of the

Directors need to meet high standard to avoid liability

  • Bennett Jones LLP
  • -
  • Canada
  • -
  • December 16 2014

The Tax Court of Canada again confirmed that directors of corporations will have a high burden to meet to establish a due diligence defence and avoid

Osler’s insights on key developments in 2014 and their implications for Canadian business.

  • Osler Hoskin & Harcourt LLP
  • -
  • Canada
  • -
  • December 9 2014

Four securities regulatory developments in 2014 warrant special attention:The Canadian Securities Administrators (CSA) proposed a new “permitted bid”