We use cookies to customise content for your subscription and for analytics.
If you continue to browse Lexology, we will assume that you are happy to receive all our cookies. For further information please read our Cookie Policy.

Search results

Order by: most recent most popular relevance



Results: 1-10 of 552

CRA updates views on taxable Canadian property look-through rule.
  • Thorsteinssons LLP
  • Canada
  • June 19 2017

A non-resident is taxable in Canada on gains realized on taxable Canadian property (TCP). TCP can potentially include shares of a corporation -


Recent News From the CRA: No Appeal Against the BP Canada Decision From the Federal Court of Appeal and More Enforcement Against Aggressive Tax Avoidance and Evasion
  • Thorsteinssons LLP
  • Canada
  • June 8 2017

I last wrote about the decision in BP Canada Energy Company v. Canada (National Revenue), 2017 FCA 61 on April 10, 2017. In that decision the Court


Limited partnership at-risk rules do not apply to partnerships as members.
  • Thorsteinssons LLP
  • Canada
  • May 30 2017

A tiered-partnership structure is fairly common in Canada: i.e., where one partnership (a top-tier Partnership) is a member of another partnership (a


Province of Ontario Introduces Legislation on Non-Resident Speculation Tax
  • Thorsteinssons LLP
  • Canada
  • May 18 2017

The Minister of Finance (Ontario) introduced Bill 134, Budget Measures Act (Housing Price Stability and Ontario Seniors’ Public Transit Tax Credit


Province of Ontario Introduces Legislation on Non-Resident Speculation Tax
  • Thorsteinssons LLP
  • Canada
  • May 18 2017

The Minister of Finance (Ontario) introduced Bill 134, Budget Measures Act (Housing Price Stability and Ontario Seniors’ Public Transit Tax Credit


Transfer-pricing audits and executive share awards.
  • Thorsteinssons LLP
  • Canada
  • May 15 2017

Within a multinational group, cross-border transfer-pricing fees often include an inter-company charge in respect of share-compensation awards made


New limits on Section 231.1(1) audit powers
  • Thorsteinssons LLP
  • Canada
  • May 12 2017

The Federal Court of Appeal recently considered the authority to conduct the inspection of books and records given by Section 231.1(1) of the Income


Canada Revenue Agency interprets construction PE article in OECD model tax treaty.
  • Thorsteinssons LLP
  • Canada, OECD
  • May 7 2017

Many of Canada's tax treaties follow Article 5(3) of the OECD's model tax treaty, which provides that a resident of the foreign treaty country


CRA says no gain or loss is recognized on making a functional currency election.
  • Thorsteinssons LLP
  • Canada
  • May 7 2017

A corporation resident in Canada may elect to compute its income for Canadian tax purposes in a currency (the Functional Currency) other than the


CRA says provincial income can be reallocated within extended reassessment period.
  • Thorsteinssons LLP
  • Canada
  • May 1 2017

In 2016-0651411I7, the CRA concluded that income originally allocated to a provincial permanent establishment (PE) can be reallocated to a different