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Results: 1-10 of 44

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

The Canadian equipment finance environment: an overview for European professionals

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

As international trade grows, financial institutions and manufacturers of equipment recognize that international sales or the globalization of their business is a requirement to staying competitive

The end of Prévost Car not the end of the story

  • Cassels Brock & Blackwell LLP
  • -
  • Canada
  • -
  • June 10 2009

The Crown has confirmed that the decision of the Federal Court of Appeal ("FCA") in Prévost Car, 2009 FCA 57, will not be appealed

The Queen v. Landrus: GAAR will not plug the holes in existing anti-avoidance rules

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

Earlier this year, the Supreme Court of Canada released its landmark general anti-avoidance rule ("GAAR") decision in Lipson v. The Queen ("Lipson"

Wabush Iron Company Limited v. The Queen drafting really matters

  • Cassels Brock & Blackwell LLP
  • -
  • Canada
  • -
  • September 14 2009

The decision in Wabush Iron Company Limited v. The Queen, 2009 DTC 1157 (Tax Court of Canada), which confirmed a substantial assessment by the Canada Revenue Agency (“CRA”), was based on an interpretation of a supply agreement

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

UPS vs. Sentinel Hill: new Supreme Court authority for returning overpaid tax to the payor

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

It was not that long ago that the Ontario Court of Appeal released an unsettling decision concerning overpaid withholding tax under Part XIII of the Income Tax Act (Canada

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

Bermuda to sign tax information exchange agreement with Canada

  • Cassels Brock & Blackwell LLP
  • -
  • Bermuda, Canada
  • -
  • June 15 2009

On May 7, 2009, Bermuda's Ministry of Finance announced that it will be signing a bilateral tax information exchange agreement ("TIEA") with Canada

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

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