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Results: 1-10 of 2,124

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


Can CRA renege on an assessing agreement?
  • Thorsteinssons LLP
  • Canada
  • January 6 2015

Occasionally, the CRA agrees with a taxpayer, in advance, to assess tax in a particular way. Those agreements arise most frequently in the context of


Superior Court allows rectification of resolutions to avoid FX gain
  • Thorsteinssons LLP
  • Canada
  • January 5 2015

In Fairmont Hotels Inc. et al v. A.G. Canada, 2014 ONSC 7302, the Superior Court of Ontario exercised its discretion to allow Canadian companies in a


Tax Court finds RRSP trustee liable for withholding tax on share purchase
  • Thorsteinssons LLP
  • Canada
  • January 5 2015

Where a non-resident of Canada sells taxable Canadian property (TCP), the purchaser of such property can be liable for withholding tax under s. 116


McKesson: taxpayer files supplementary factum
  • Dentons
  • Canada
  • January 7 2015

As expected, the taxpayer has filed a Supplementary Memorandum of Fact and Law in its transfer pricing appeal in the Federal Court of Appeal. Earlier


Tax Court holds GST not payable on certain special mutual fund trust distributions
  • Thorsteinssons LLP
  • Canada
  • January 7 2015

In the recent decision in Invesco Canada Ltd. v. Canada (2014 TCC 375), the Tax Court of Canada held that certain management fee reductions paid on a


Step Canada: CRA provides update on audit activities
  • Dentons
  • Canada
  • June 20 2014

The Society of Trust and Estate Practitioners (STEP Canada) held its 16th annual national conference on June 16-17 in Toronto. As it has in previous


Tax Court: mini storage not a “small business”
  • Dentons
  • Canada
  • October 20 2014

The small business deduction ("SBD") is a tax-preference provided to certain privately-held Canadian corporations, and only in respect of certain


Rectification: current developments regarding this useful judicial remedy
  • Miller Thomson LLP
  • Canada
  • July 31 2014

Rectification is an equitable remedy that allows for judicial corrections of a document that, due to errors in drafting, does not reflect the true


“Half-loaf” gone wrong: Gervais, G. et al. v. The Queen (“Gervais”).
  • Miller Thomson LLP
  • Canada
  • July 31 2014

A recent case from the Tax Court of Canada ruled against a taxpayer who implemented a tax plan known as the "half-loaf" plan. The purpose of a