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Results: 1-10 of 73

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”

Why would anyone want an unlimited liability company?

  • Miller Thomson LLP
  • -
  • Canada, USA
  • -
  • October 31 2014

An unlimited liability company ("ULC") is a common entity US businesses use as a Canadian subsidiary or to hold Canadian assets. This can seem

Court rules in case involving director’s liability for income tax and other amounts

  • Miller Thomson LLP
  • -
  • Canada
  • -
  • October 31 2014

The Income Tax Act (Canada) (the "Act") provides that directors of a corporation, including a not-for-profit corporation, are liable for income tax

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