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Appeal court orders retrial on Heron Bay
- Borden Ladner Gervais LLP
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- Canada
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- August 9 2010
In a judgment in Heron Bay Investments Ltd. v. The Queen (2010 FCA 203), delivered on July 26, 2010, the Canadian Federal Court of Appeal found that there was a “want of procedural fairness” in the proceedings of the Tax Court which resulted in its decision of September 8, 2009 (2009 TCC 337) and, as requested by the appellant, Heron Bay, in its pleadings, returned the matter to the Tax Court “for retrial by a different judge”
Court of appeal accepts GlaxoSmithKline arguments in transfer pricing case
- Borden Ladner Gervais LLP
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- Canada
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- July 29 2010
On July 26, 2010, the Canadian Federal Court of Appeal released its decision in the case of GlaxoSmithKline Inc
U.S. LLCs should consider refund claims for branch tax paid to Canada
- Borden Ladner Gervais LLP
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- Canada, USA
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- July 22 2010
On April 8, 2010, the Tax Court of Canada found in favour of the taxpayer in TD Securities (USA) LLC v. The Queen
Opportunities abound in Canadian capital markets a case for Indian entrepreneurs
- Borden Ladner Gervais LLP
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- Canada, India
- -
- April 30 2010
The Canadian capital markets offer substantial opportunities for Indian companies interested in tapping into foreign capital markets
Canada-U.S. treaty could impact Latin American investments in North America
- Borden Ladner Gervais LLP
- -
- Canada, USA
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- April 13 2010
Any structuring of investments by a Latin American investor into Canada through the U.S., or any acquisition of a U.S. business which either operates a Canadian business or which receives Canadian-sourced payments, and any decision to acquire a Canadian business or to expand Canadian operations where business arrangements and particularly intercompany funding result in a U.S. resident receiving Canadian-sourced cash flows should include a review of how the Limitation on Benefits (“LOB”) rules in the recently revised Canada-U.S. Income Tax Convention (the “Treaty”) may apply
Continuing issues for U.S. LLCs investing into Canada
- Borden Ladner Gervais LLP
- -
- Canada, USA
- -
- March 18 2010
The Canada Revenue Agency (“CRA”), on February 11, 2010, issued a Technical Memorandum on the application by Canada of the look-through rule in Article IV(6) of the Canada-U.S. Income Tax Convention (the “Treaty”) to U.S. limited liability companies (LLCs) and their members
Crown appeals General Electric case
- Borden Ladner Gervais LLP
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- Canada
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- March 18 2010
On January 4, 2010, the Crown deposited with the Federal Court of Appeal its notice of appeal of the Tax Court of Canada's judgment in the case of General Electric Capital Canada Inc
Canada’s Supreme Court to hear GAAR appeal
- Borden Ladner Gervais LLP
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- Canada
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- February 9 2010
The concept of paid-up capital is important for Canadian tax purposes in that, unlike certain of its treaty partners, Canada permits corporations to return capital to shareholders (even if they have accumulated earnings and profits for tax purposes), without payment of Canadian non-resident withholding tax
CanadaU.S. Treaty could impact Latin American investments in North America
- Borden Ladner Gervais LLP
- -
- Canada, USA
- -
- January 14 2010
Any structuring of investments by a Latin American investor into Canada through the U.S., or any acquisition of a U.S. business which either operates a Canadian business or which receives Canadian-sourced payments, and any decision to acquire a Canadian business or to expand Canadian operations where business arrangements and particularly intercompany funding result in a U.S. resident receiving Canadian-sourced cash flows should include a review of how the Limitation on Benefits (“LOB”) rules in the recently revised Canada-U.S. Income Tax Convention (the “Treaty”) may apply
CanadaU.S. treaty could impact Japan-North American investments
- Borden Ladner Gervais LLP
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- Canada, Japan, USA
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- January 14 2010
Any structuring of investments by Japanese investor into Canada through the U.S., or any acquisition of a U.S. business which either operates a Canadian business or which receives Canadian-sourced payments, and any decision to acquire a Canadian business or to expand Canadian operations where business arrangements and particularly intercompany funding result in a U.S. resident receiving Canadian-sourced cash flows should include a review of how the Limitation on Benefits (“LOB”) rules in the recently revised Canada-U.S. Income Tax Convention (the “Treaty”) may apply
Current Search
- Workarea - Corporate Tax
- Jurisdiction - Canada
- Author - Elinore J. Richardson