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Results: 1-10 of 45

Flow-through shares: investing in a volatile market

  • Cassels Brock & Blackwell LLP
  • -
  • Canada
  • -
  • December 1 2008

During a time of market volatility, investors may be reluctant to part with their money; however, there may still be some appetite where tax deductions or credits exist

Notice requirements for eligible dividends

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

New tax rules enacted earlier this year allow Canadian corporations to pay eligible dividends that are taxed at lower rates in the hands of individual shareholders as long as stringent notice requirements are met

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

New effective date for proposed exemption from withholding tax under the Income Tax Act (Canada)

  • Cassels Brock & Blackwell LLP
  • -
  • Canada, USA
  • -
  • November 23 2007

The Canadian federal budget of March 19, 2007 announced that Canadian and U.S. officials had agreed in principle on major elements of an updated Canada-U.S. Tax Convention (the "Treaty") which would eliminate withholding tax on arm's length interest, and, subject to a phase-in, on non-arm's length interest

New amendment to the Income Tax Act (Canada)

  • Cassels Brock & Blackwell LLP
  • -
  • Canada
  • -
  • February 1 2008

On December 14, 2007, the Income Tax Act (Canada) ("ITA") was amended to eliminate withholding tax on interest paid by a Canadian resident to a non-resident creditor or lender who deals at arm's-length with the payer, regardless of the recipient's country of residence

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

Federal Court of Appeal upholds Prévost Car: implications for treaty planning and offshore structures

  • Cassels Brock & Blackwell LLP
  • -
  • Canada
  • -
  • March 5 2009

The long-awaited recent decision of the Federal Court of Appeal ("FCA") in Prévost Car, 2009 FCA 57, upholds the principle that, in determining the applicable withholding rate on dividends, interest, royalties and other payments to treaty countries such as Holland, Luxembourg and other intermediary jurisdictions with low withholding tax rates, Canada Revenue Agency ("CRA") cannot ignore the intermediary jurisdiction and apply the higher rate that may be applicable had the payment been made directly

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

An overview of Canadian tax credits for non-indigenous film and television production

  • Cassels Brock & Blackwell LLP
  • -
  • Canada
  • -
  • July 10 2008

Canada, often referred to as “Hollywood North”, continues as a leading innovator in the development and implementation of public sector incentives for film and television production

Proposed conversion rules for income trusts

  • Cassels Brock & Blackwell LLP
  • -
  • Canada
  • -
  • July 25 2008

On July 14, 2008, the Department of Finance released the long-awaited draft amendments (the "Conversion Amendments") to the Income Tax Act (Canada) (the "Act"), allowing the conversion of certain income funds into corporations on a tax-deferred basis