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Results: 1-10 of 36

Ontario budget 2013: tax measures target aggressive tax planning

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • May 3 2013

On May 2, 2013, Finance Minister Charles Sousa tabled the Ontario minority government's 2013 Budget entitled "A Prosperous & Fair Ontario" (Budget

Employer-provided parking: when is it a taxable benefit to the employee?

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • October 1 2012

Employee compensation may include not only salary and wages but also non-cash compensation such as stock options and non-monetary benefits such as supplemental health and life insurance

Finance releases draft legislation to implement stapled securities rules

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • September 6 2012

On July 25, 2012, the Department of Finance Canada (“Finance”) released draft legislation to amend the Income Tax Act (Canada) (the “Act”) to eliminate the tax advantages of stapled security transactions

Finance recommends relieving changes to prohibited investment rules for RRSPs, RRIFs and TFSAs

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • June 19 2012

On June 12, 2012, the Department of Finance (“Finance”) sent a letter to the Joint Committee on Taxation of the Canadian Bar Association and the Canadian Institute of Chartered Accountants, in which it agreed to recommend significant relieving changes to the prohibited investment rules in Part XI.01 of the Income Tax Act (Canada) (the “Tax Act”) as they apply to investments made by RRSPs, RRIFs and TFSAs (collectively, “Registered Plans”

Tax court finds unanimous shareholders’ agreement affected legal control of a corporation its non-resident shareholders

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • June 5 2012

Determining who controls a corporation is relevant to determining the availability of certain tax benefits provided by the Income Tax Act (Canada

Central management and control test determines trust residence for Canadian tax purposes

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • April 16 2012

On April 12, 2012, the Supreme Court of Canada (“SCC”) dismissed the taxpayer’s appeal in St. Michael Trust Corp. v. The Queen

Primer on transfer pricing audits

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • March 9 2012

Transfer pricing attracts a lot of attention from tax authorities, generally because large amounts are often involved and most countries are concerned with protecting their own tax base

Goodwill hunting: identifying and allocating value to goodwill on the sale of a business

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • February 16 2012

One of the more significant issues in an asset purchase deal is the allocation of purchase price among the assets being purchased

Implications of Copthorne on tax planning

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • December 21 2011

In Copthorne, the Supreme Court of Canada addressed anticipatory tax planning under the general-anti avoidance rule

CRA reaffirms position on activities carried on outside the municipality

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • December 14 2011

A recently released CRA technical interpretation provides municipal electricity utilities (MEUs) and other municipally-owned corporations (MOCs) with continuing reassurance regarding the CRA’s application of the geographic source of income test in paragraphs 149(1)(d.5) and 149(1)(d.6) of the Income Tax Act (Canada) (the “Act”), and presents some interesting opportunities for expanding their business footprint

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