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New Income Tax Folio S6-F1-C1: Residence of a Trust or Estate
  • Miller Thomson LLP
  • Canada
  • January 12 2015

Effective September 19, 2014, the Canada Revenue Agency (the "CRA") released a new Income Tax Folio on the Residence of a Trust or Estate. This


Tax deduction for the depreciation in the market value of patents
  • Smart & Biggar/Fetherstonhaugh
  • Canada
  • April 8 2015

Under Canada's tax laws, a taxpayer may deduct a "terminal loss" from its taxable income, where (i) the taxpayer has incurred a capital cost in


Osler’s insights on key developments in 2014 and their implications for Canadian business.
  • Osler Hoskin & Harcourt LLP
  • Canada
  • December 9 2014

Four securities regulatory developments in 2014 warrant special attention:The Canadian Securities Administrators (CSA) proposed a new “permitted bid”


Secured creditors can appeal to Tax Court on behalf of a bankrupt
  • Bennett Jones LLP
  • Canada
  • December 2 2014

The Tax Court of Canada recently confirmed in International Hi-Tech Industries Inc v The Queen, 2014 TCC 198, that in certain circumstances a secured


Legge: improper pleading fatal to Crown’s case
  • Dentons
  • Canada
  • December 9 2014

What must the Crown plead and how must she plead it? This question became an issue in the Tax Court's recent decision in Legge v. The Queen (2014 TCC


The assumption of rehabilitation liabilities as consideration given on the acquisition of mining property and capital assets
  • ENSafrica
  • Canada, South Africa
  • October 22 2014

During December 2013, SARS released a draft discussion paper in which it set out its application of the relevant tax law, in relation to the tax


Surrender of stock option by executive generated a capital gain
  • Thorsteinssons LLP
  • Canada
  • December 8 2014

In The Estate of the Edward S. Rogers v. The Queen, 2014 TCC 348, the Tax Court of Canada (TCC) held that the surrender of stock options in 2007 to


Lau: BC SC corrects articles of incorporation after $17.3 million reassessment
  • Dentons
  • Canada
  • January 1 2015

Many tax rectification cases address situations in which certain transaction documents contain errors that do not accord with the parties' intent to


Tax Court finds gain on hedge to protect balance sheet equity was a capital gain
  • Thorsteinssons LLP
  • Canada
  • March 2 2015

In the CRA’s long-standing view, proceeds realized on a hedge contract cannot be on capital account if there is no sale (or proposed sale) of the


Techtronic Industries Canada Inc. decision: application of Incoterms and other similar commercial terms in QST matters
  • Stikeman Elliott LLP
  • Canada
  • October 27 2014

In a decision rendered last July 14th, the Court of Québec established the impact of commercial terms like "free on board" (F.O.B.) (North America