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Information-gathering and tax audits by a revenue authority could there be an ulterior purpose?
- DLA Cliffe Dekker Hofmeyr
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- Canada
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- May 10 2013
The Canadian Federal Court of Appeal's (FCA) recent judgment in MNR v RBC Life Insurance Co, 2013 FCA 50 (decided on 21 February 2013) condemned the
Transactions to minimize the tax implications of the twenty-one-year rule for trusts
- Fasken Martineau DuMoulin LLP
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- Canada
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- April 30 2013
For income tax purposes, trusts are generally deemed to dispose of their capital property every 21 years following their creation, resulting in the
Budget 2013 a new federal consumer code
- McCarthy Tétrault LLP
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- Canada
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- March 22 2013
As part of its 2013 Budget tabled in Parliament yesterday, the federal government has indicated its intention to develop a "comprehensive financial
Revenue Minister can't use audit to "chill" business
- Borden Ladner Gervais LLP
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- Canada
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- March 13 2013
In MNR v. RBC Life Insurance Company et al., 2013 FCA 50, the Federal Court of Appeal held that the Minister of National Revenue could not use her
2012 so far: Bill C-45 and amendments to financial services legislation
- Blake Cassels & Graydon LLP
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- Canada
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- November 13 2012
On October 18, 2012, the Honourable Jim Flaherty, Minister of Finance, introduced in Parliament the Jobs and Growth Act, 2012 (Bill C-45), the second omnibus legislation in 2012 implementing the provisions of the federal Budget tabled on March 29, 2012
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
- -
- 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
Manitoba introduces retail sales tax on insurance contracts
- Cassels Brock & Blackwell LLP
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- Canada
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- October 23 2012
The province of Manitoba recently enacted legislation imposing a 7 retail sales tax on premiums payable on taxable insurance contracts, effective as of July 15, 2012
Doing business in Canada
- Gowling Lafleur Henderson LLP
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- Canada
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- September 17 2012
Unlike the United States, Canada was not created by a unilateral declaration of independence from the colonial occupation of England
Federal budget 2012
- Aird & Berlis LLP
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- Canada
- -
- March 30 2012
The thin capitalization rules limit the deductibility of an interest expense of a Canadian resident corporation in respect of debts owing to a specified non-resident shareholder generally where the debt to equity ratio in respect of debts owing to specified non-residents exceeds a ratio of 2-to-1
Personal income tax measures
- Osler, Hoskin & Harcourt LLP
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- Canada
- -
- March 29 2012
Under the rules of the Act, the dividend tax credit is available to shareholders to help relieve the double taxation of corporate income, which is subject to tax at both the corporate level and at the personal shareholder level
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