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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
Supreme Court of Canada decides on trust tax residency
- Osler, Hoskin & Harcourt LLP
- -
- Canada
- -
- April 13 2012
The Supreme Court of Canada dismissed the taxpayers’ appeal in Fundy Settlement (also known as Garron or St. Michael Trust Corp.), deciding on April 12, 2012 that the relevant trusts were resident in Canada rather than Barbados for purposes of Canada’s Income Tax Act
Ontario releases final regulations re pension division on marriage breakdown
- Osler, Hoskin & Harcourt LLP
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- Canada
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- July 4 2011
On June 22, 2011, the Ontario government published final regulations governing the division of pensions on marriage breakdown
Ontario draft regulations re pension division on marriage breakdown
- Osler, Hoskin & Harcourt LLP
- -
- Canada
- -
- May 13 2011
The Ontario government's reform of the law governing pension division on marriage breakdown appears to finally be moving forward with the release of long-awaited draft regulations
New Canada Revenue Agency position on Barbados exempt insurance companies
- Osler, Hoskin & Harcourt LLP
- -
- Canada
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- November 12 2010
The Canada Revenue Agency (CRA) recently indicated that Barbados "exempt insurance companies" (EICs) may be considered "liable to tax" in Barbados within the meaning of Article IV of the Canada-Barbados tax treaty
Income trust conversions
- Osler, Hoskin & Harcourt LLP
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- Canada
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- December 9 2009
The Canadian income trust market has always been defined by continual changes in Canadian tax rules
Supreme Court of Canada rules against taxpayer in Lipson, dismisses leave to appeal in Mackay
- Osler, Hoskin & Harcourt LLP
- -
- Canada
- -
- January 15 2009
Today, Canada's highest court denied leave to appeal in Mackay, a case in which the Federal Court of Appeal held that the general anti-avoidance rule (“GAAR”) under the Income Tax Act (Canada) applied to a structured acquisition that resulted in the transfer of losses between arm's-length parties
