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Results: 1-10 of 259

Prescient Foundation v. M.N.R.

  • Miller Thomson LLP
  • -
  • Canada
  • -
  • May 31 2013

On May 1, 2013 the Federal Court of Appeal delivered its judgement in Prescient Foundation v. M.N.R.: 2013 FCA 120. The judgement was delivered by Mr

Court criticises CRA for delaying assessment of donation shelter donations

  • Miller Thomson LLP
  • -
  • Canada
  • -
  • May 31 2013

In a recent case, the Federal Court confirmed that the CRA is obliged to examine and assess a tax return with "all due dispatch" even if the taxpayer

Housing corporations for the aged

  • Miller Thomson LLP
  • -
  • Canada
  • -
  • May 31 2013

The Income Tax Act has special rules relating to corporations that provide low income housing for the aged. While some of these corporations are

No consolidated taxation of corporate groups in Canada

  • Miller Thomson LLP
  • -
  • Canada
  • -
  • May 22 2013

Canada does not have a formal system of corporate group taxation like the United States and other jurisdictions. Although Canadian corporate groups

NPO update

  • Miller Thomson LLP
  • -
  • Canada
  • -
  • April 29 2013

Over the past several months, CRA has released two technical interpretations commenting on aspects of the tax exemption for non-profit organizations

New budget rules for non-residents carrying on business in Canada

  • Miller Thomson LLP
  • -
  • Canada
  • -
  • April 18 2013

On March 21, 2013, the Minister of Finance, Jim Flaherty, tabled the 2013 Federal Budget (the "Budget") entitled Jobs, Growth and Long-Term

Recent proposed changes to rules applicable to personal services business

  • Miller Thomson LLP
  • -
  • Canada
  • -
  • April 17 2013

Back in the 1970s, while the Montreal Canadiens were dominating the NHL, Ken Dryden backstopped the Canadiens to win six Stanley Cups. While much can

SCC tax cases 2012 in review: the death of Moldowan and the first Transfer Pricing decision

  • Miller Thomson LLP
  • -
  • Canada
  • -
  • April 17 2013

There are only a few tax cases that make it to the Supreme Court of Canada ("SCC"). Indeed, any party that has sought leave to appeal to the SCC

Overview of limitation on benefits article in Canada-U.S. Tax Treaty

  • Miller Thomson LLP
  • -
  • Canada, USA
  • -
  • April 17 2013

The Canada-United States Tax Treaty (the "Tax Treaty") is unique among Canada's tax treaties in its approach to prevent "treaty shopping". Treaty

Canadian renewable & conservation expense “green” energy tax incentives

  • Miller Thomson LLP
  • -
  • Canada
  • -
  • April 17 2013

This article is an overview of the Canadian income tax considerations relevant to Canadian renewable and conservation expenses ("CRCE") initially

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