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Results: 1-10 of 44

General Electric Capital Canada wins tax case on deduction of guarantee fees

  • Cassels Brock & Blackwell LLP
  • -
  • Canada
  • -
  • January 13 2010

The Tax Court of Canada's recent decision in General Electric Capital Canada Inc. v. The Queen provides an example of the court's application of transfer pricing rules in the Income Tax Act (Canada) (the "ITA") in the context of a guarantee arrangement between a non-resident parent and a Canadian subsidiary

Changes to thin capitalization rules: concern for US finance and non-finance companies with Canadian subsidiaries

  • Cassels Brock & Blackwell LLP
  • -
  • Canada
  • -
  • June 14 2012

An often overlooked change proposed in the Canadian federal budget of March, 2012, may have a significant impact on how Canadian subsidiaries of foreign corporations are financed

Federal Budget 2008: compliance relief for cross-border investments

  • Cassels Brock & Blackwell LLP
  • -
  • Canada
  • -
  • March 31 2008

On February 26, 2008, the Federal government tabled its Budget, in which it proposes a variety of tax changes, including measures to improve the efficiency of the compliance system for non-residents disposing of taxable Canadian property

Things just changed: new considerations for establishing a presence in Canada

  • Cassels Brock & Blackwell LLP
  • -
  • Canada, USA
  • -
  • December 3 2007

The signing of the Fifth Protocol to the Canada-U.S. Tax Treaty (the "Treaty") and the coming into force of the unlimited liability company provisions of the British Columbia Business Corporations Act in October 2007 may affect the manner in which American business enters the Canadian market

Lipson v. Canada - a sworded tale

  • Cassels Brock & Blackwell LLP
  • -
  • Canada
  • -
  • February 19 2009

In a split decision rendered in January 2009, the Supreme Court of Canada ("SCC") applied the general anti-avoidance rule under section 245 of the Income Tax Act (Canada) (the "Act") to deny interest deductibility in the highly anticipated Lipson decision

TD Securities (USA) LLC v. The Queen - Canada Revenue Agency loses on denying treaty benefits to a LLC

  • Cassels Brock & Blackwell LLP
  • -
  • Canada
  • -
  • April 19 2010

The Tax Court of Canada recently released its judgment in TD Securities (USA) LLC v. The Queen

Ontario adopts new wealth tax

  • Cassels Brock & Blackwell LLP
  • -
  • Canada
  • -
  • June 25 2012

On June 20, 2012, Ontario’s legislature passed a bill that introduces a 2 tax increase on the taxable income of individuals in excess of $500,000

Supreme Court of Canada grants leave in tax case involving contingent liabilities

  • Cassels Brock & Blackwell LLP
  • -
  • Canada
  • -
  • July 4 2012

In a rare oral hearing, the Supreme Court of Canada granted leave in the case of Daishowa-Marubeni International Ltd. v. The Queen

TD Securities (USA) LLC v. The Queen - Crown does not seek appeal

  • Cassels Brock & Blackwell LLP
  • -
  • Canada
  • -
  • May 14 2010

As we recently reported, the Tax Court of Canada released its judgment in TD Securities (USA) LLC v. The Queen on April 8, 2010, extending benefits under the Canada-US Income Tax Convention (the "US Treaty") to a limited liability company (the "LLC") established under the laws of the United States

Canada Revenue Agency will no longer automatically back date a voluntary GSTHST registration

  • Cassels Brock & Blackwell LLP
  • -
  • Canada
  • -
  • February 15 2012

Registration for the GSTHST is mandatory when a person becomes liable to charge and collect the GSTHST as a supplier of goods or services

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