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Distributing an interest in a life insurance policy on a corporate wind-up
  • Miller Thomson LLP
  • Canada
  • November 20 2015

In a recent Interpretation (CRA Views No. 2015-0573841C6) (the “Interpretation”), the Canada Revenue Agency (“CRA”) discussed its position on a

ACB adjustments for foreign affiliate shares held through partnerships
  • Davies Ward Phillips & Vineberg LLP
  • Canada
  • November 5 2015

Recent CRA comments at the May 2014 IFA international tax seminar and a subsequently released CRA technical interpretation highlight anomalies in the

Rectification in a tax context: the intention standard prevails
  • Blake Cassels & Graydon LLP
  • Canada
  • November 2 2015

A drafting mistake in an agreement can result in significant and unintended tax consequences. In the recent case of Baytex Energy Ltd. v. Canada

Are dividends between related corporations still "safe"?
  • Fogler Rubinoff LLP
  • Canada
  • October 29 2015

The 2015 Federal Budget proposed changes that contain a hidden danger which may significantly impede the ability to move cash and other assets

Ontario court rectifies partnership alignment election
  • Thorsteinssons LLP
  • Canada
  • October 19 2015

In Telus Communications Inc. et. al. V. Canada (Attorney General), 2015 ONSC 6245 (copy attached), a corporate group filed a multi-tier alignment

British Columbia court says CRA could not reassess beyond normal reassessment period
  • Thorsteinssons LLP
  • Canada
  • October 19 2015

In Inwest Investments Ltd. v. The Queen, 2015 BCSC 1375 (copy attached), a holding company sold shares for a large capital gain. The company adopted

Doing business in Atlantic Canada
  • Stewart McKelvey
  • Canada
  • September 29 2015

Canada’s four most easterly provinces form the region known as Atlantic Canada and has a population of approximately 2.3 million people. These

Doing business in Canada
  • Blake Cassels & Graydon LLP
  • Canada
  • September 22 2015

This Guide provides non-Canadians with an introduction to the laws and regulations that affect the conduct of business in Canada and, in particular

The taxation of various Canadian acquisition vehicles
  • Norton Rose Fulbright Canada LLP
  • Canada
  • September 17 2015

Often the determination of what type of entity to acquire a business with is driven by the most tax efficient structure. Here we will review some of

Hybrid entity classification following the anson decision
  • Fasken Martineau DuMoulin LLP
  • Canada, OECD, United Kingdom
  • September 10 2015

For many years, both the Canada Revenue Agency (CRA) and Her Majesty's Revenue and Customs (HMRC) have treated limited liability companies (LLC