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SCC adopts commercial approach in allowing the appeal by Daishowa-Marubeni International Ltd.

Osler, Hoskin & Harcourt LLP
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Canada
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May 24 2013

On May 23, 2013, the Supreme Court of Canada released its decision in Daishowa-Marubeni International Ltd. v. Canada. The decision considers whether

Plan Nord Québec’s new mining royalty regime

Osler, Hoskin & Harcourt LLP
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Canada
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May 9 2013

On May 6, 2013, the Québec government revealed its long-awaited mining royalty and tax regime in an official document titled “A New Mining Tax

President Obama’s pension cap: who would really be affected?

Osler, Hoskin & Harcourt LLP
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Canada
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May 7 2013

The President's recent budget proposal would impose a new cap on tax-favored retirement benefits. Annual contributions and accruals under tax-favored

Budget briefing 2013

Osler, Hoskin & Harcourt LLP
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Canada
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March 21 2013

The Honourable Jim Flaherty, Minister of Finance, tabled Budget 2013 today. In his Budget Speech, the Minister lauded Canada's economic strength and

Plan Nord Québec tables a consultation paper on its proposed new mining royalty regime

Osler, Hoskin & Harcourt LLP
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Canada
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March 13 2013

On March 7, 2013, the Québec government released a consultation paper containing its proposed changes to the Québec mining royalty and tax regime in

Foreign affiliate dumping regime revised in Bill C-45

Osler, Hoskin & Harcourt LLP
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Canada
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November 6 2012

On October 18, 2012, the Canadian Government took a further step toward implementing new “foreign affiliate dumping” rules (the FA dumping rules) that will have a significant impact on foreign-based multinationals with Canadian subsidiaries and on acquisitions by non-resident corporations of Canadian corporations that derive the significant majority of their value from foreign operations

Canadian government moves to implement amended non-resident trust and offshore investment fund property rules

Osler, Hoskin & Harcourt LLP
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Canada
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November 5 2012

On October 24, 2012, the Federal Minister of Finance released a detailed Notice of Ways and Means Motion to implement outstanding technical tax amendments, including significant amendments to Canada’s income tax rules applicable to non-resident trusts (NRTs) and offshore investment funds (the Proposals

Commentary on October 24, 2012 Notice of Ways and Means Motion relating to tax matters - insurance corporations

Osler, Hoskin & Harcourt LLP
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Canada
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November 1 2012

Except with respect to one proposal in respect of policy reserves for segregated life insurance policies, most of the changes to section 138 of the Act and Part XIV of the Income Tax Regulations are clarifying changes or changes made to repeal obsolete provisions

Commentary on October 24, 2012 Notice of Ways and Means Motion relating to tax matters - foreign spin-offs

Osler, Hoskin & Harcourt LLP
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Canada
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November 1 2012

Section 86.1 provides a tax deferral with respect to distributions to Canadian resident shareholders of spin-off shares by eligible foreign corporations

Commentary on October 24, 2012 Notice of Ways and Means Motion relating to tax matters - shares issued as consideration for property or services (proposed section 143.3)

Osler, Hoskin & Harcourt LLP
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Canada
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November 1 2012

The Tax Court of Canada held in Alcatel Canada Inc. v. The Queen, 2005 2 C.T.C. 2001 (TCC), that the taxpayer was entitled to an investment tax credit in respect of the value of stock option benefits granted to its employees because the stock option benefits constituted “expenditures” made in respect of an expense for salary and wages notwithstanding that the taxpayer made no cash outlay in respect of the stock option benefits

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