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Too much wiggle room in Wigglesworth? Advisor penalties under Income Tax Act not criminal offences in nature and don’t engage protections under s. 11 of the Charter, says Federal Court of Appeal in Guindon

Dentons
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Canada
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June 18 2013

On June 12, 2013, the Federal Court of Appeal released its decision in Canada v. Guindon (2013 FCA 153). The court was tasked with examining the

Gain on shares of Canadian Pubco not taxable to non-resident partners

Thorsteinssons LLP
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Canada
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June 17 2013

In 2010-0385931I7 (released last week), the Rulings Directorate of the Canada Revenue Agency (Rulings) was asked to consider a case where a

TCC finds that Pubco had de facto control of R&D company

Thorsteinssons LLP
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Canada
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June 17 2013

In Lyrtech RD Inc. v. The Queen, 2013 TCC 12, the Tax Court of Canada (TCC) held that a public company (Pubco) had de facto control of a Canadian

CRA considers whether 5 treaty withholding tax rate applies to deemed dividend

Thorsteinssons LLP
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Canada
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June 17 2013

In 2013-0486011E5, the CRA concluded that the preferential 5 dividend withholding tax (WHT) rate under the Canada-Netherlands tax treaty (Treaty

Making the crime fit the punishment

Thorsteinssons LLP
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Canada
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June 14 2013

The Federal Court of Appeal's recent decision in The Queen v. Guindon attempts to answer the question: when is an intentional action criminal in

Supreme Court rules on the taxation of assumed obligations in asset purchase transactions

Stikeman Elliott LLP
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Canada
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June 12 2013

The Supreme Court of Canada recently released a decision which overturned previous court decisions and confirmed that the assumption of reforestation

Daishowa: characterizing the assumption of obligations when determining the proceeds from disposition

Gowling Lafleur Henderson LLP
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Canada
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June 7 2013

In Daishowa-Marubeni International Ltd. v Canada, 2013 SCC 29, the Supreme Court of Canada ("SCC") held 9:0 that Daishowa-Marubeni International's

Consultation begins on eliminating tax benefits of trusts and certain estates

Borden Ladner Gervais LLP
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Canada
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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

Life insurance policy: how to extract funds from a corporation with no tax impact

Lavery de Billy LLP
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Canada
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June 6 2013

Individual shareholders who wish to withdraw funds from a corporation can face some tax challenges that are sometimes difficult to overcome

Canada Revenue Agency provides update on rulings and GAAR at Toronto centre CRA & professionals group breakfast seminar

Dentons
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Canada
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June 6 2013

On June 6, 2013, at the Toronto Centre CRA & Professionals Breakfast Seminar, the Canada Revenue Agency discussed (a) recent developments at the

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Search results

Too much wiggle room in Wigglesworth? Advisor penalties under Income Tax Act not criminal offences in nature and don’t engage protections under s. 11 of the Charter, says Federal Court of Appeal in Guindon

Gain on shares of Canadian Pubco not taxable to non-resident partners

TCC finds that Pubco had de facto control of R&D company

CRA considers whether 5 treaty withholding tax rate applies to deemed dividend

Making the crime fit the punishment

Supreme Court rules on the taxation of assumed obligations in asset purchase transactions

Daishowa: characterizing the assumption of obligations when determining the proceeds from disposition

Consultation begins on eliminating tax benefits of trusts and certain estates

Life insurance policy: how to extract funds from a corporation with no tax impact

Canada Revenue Agency provides update on rulings and GAAR at Toronto centre CRA & professionals group breakfast seminar

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