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Results: 1-10 of 11

Consultation begins on eliminating tax benefits of trusts and certain estates

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • June 6 2013

In the March 2013 Federal Budget, the government announced its intention to consult on possible measures to eliminate the tax benefits arising from

Leaked documents suggest some taxpayers should consider voluntary disclosures

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • May 16 2013

On April 3 2013 several media outlets, including the Canadian Broadcasting Corporation (CBC), revealed the existence of leaked financial documents

BLG Monthly Update

  • Borden Ladner Gervais LLP
  • -
  • Argentina, Australia, Canada, United Kingdom, USA
  • -
  • December 19 2012

The BLG Monthly Update is a digest of recent developments in the law which Neil Guthrie, our National Director of Research, thinks you will find

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

Federal budget 2011: stay the course, on the way to the polls

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • March 23 2011

The Honourable James Flaherty, Minister of Finance Canada, tabled the Conservative government's 2011 federal budget (Budget 2011) on March 22, 2011 (Budget Day

Canada’s new tax avoidance transaction reporting regime

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • January 25 2011

Following similar initiatives by Quebec, the U.S, the U.K. and Australia, Canada has proposed a regime of mandatory disclosure for certain tax avoidance transactions entered into after 2010, as well as transactions that are part of a series of transactions that began before 2011 but is completed after 2010

Barbados spousal trust strategy fails Canadian trust and GAAR tests

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • October 7 2009

In Paul Antle and Renee Marquis-Antle Spousal Trust v. The Queen, the Tax Court considered a series of transactions implemented by a Canadian resident taxpayer known as a “capital property step-up strategy”

Central management and control determines trust residence

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • September 23 2009

In Garron, M. et al. v. The Queen, the Tax Court of Canada considered whether two Barbados trusts (the “Trusts”) were entitled to claim the benefit of the capital gains exemption in Article XIV(4) of the Canada-Barbados Income Tax Convention (the “Treaty”) on their dispositions to an arm’s length purchaser of shares of two Canadian holding corporations which indirectly owned a Canadian automotive parts manufacturing and assembly business

B.C. prosecution for false residency fails

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • August 21 2009

In a Taxpayers' Alert issued in March 2007, the Canada Revenue Agency indicated "Where You Live Matters: The Canada Revenue Agency (CRA) is warning Canadians to properly indicate their province or territory of residence on their tax returns."

Canada’s non-resident trust rules may catch foreign commercial trusts with canadian investors

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • June 30 2008

Canada’s non-resident trust rules (the "NRT Rules") have been a matter of extensive review in hearings of the Standing Senate Committee on Banking, Trade and Commerce in recent months