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Goodwill sale: everything must go!
  • Thorsteinssons LLP
  • Canada
  • August 12 2016

Canada's Budget 2016 proposes to repeal the existing eligible capital property (ECP) regime in favour of a new class of depreciable capital property


Proposed GSTHST amendments relating to drop shipments
  • Osler Hoskin & Harcourt LLP
  • Canada
  • August 8 2016

The drop shipment rules found in section 179 of the Excise Tax Act (the Act) essentially allow an unregistered non-resident person to acquire goods


Alberta court confirms arm’s length standard does not govern interest on inter-company loans within Canada
  • Thorsteinssons LLP
  • Canada
  • August 8 2016

In ENMAX Energy Corporation v Alberta, 2016 ABQB 334, an Alberta court usefully confirmed that the arm's length standard does not govern the interest


What will become of the U.S. DebtEquity Proposal?
  • Osler Hoskin & Harcourt LLP
  • Canada, USA
  • August 5 2016

When the U.S. Treasury Department issued proposed debtequity regulations on April 4, 2016 (the Proposed 385 Regulations), the impact of these rules


Tax Court Allows Deduction for Advisory Fees in M&A Transaction
  • Bennett Jones LLP
  • Canada
  • July 22 2016

The Tax Court of Canada has recognized in a recent case that “oversight expenses” - notably investment banking and other professional advisory fees


Selling a business: Top five tips revealed
  • Gowling WLG
  • Canada
  • July 21 2016

Business owners are often looking for opportunities to improve and grow their businesses, or in some cases, refine their exit strategies. If you’re a


The Federal Court of Appeal clarifies the de facto control test
  • Gowling WLG
  • Canada
  • June 14 2016

Control is a concept that is relevant for a number of income tax rules. There are two types of control: de jure and de facto control. Determining de


Applications for leave to appeal dismissed - 10 June 2016
  • Gowling WLG
  • Canada
  • June 10 2016

The applicant sought reconsideration of a decision of the Public Service Labour Relations and Employment Board (“Board”) dated February 21, 2008. She


SCC rules s. 231.2(1) requirements unconstitutional as applied to taxpayers’ legal advisors
  • Thorsteinssons LLP
  • Canada
  • June 5 2016

The Canada Revenue Agency (CRA) has extremely broad powers to audit Canadian taxpayers, which is a practical necessity in any self-reporting tax


Sell now to avoid paying higher taxes upon disposition of goodwill and other intangibles
  • Dentons
  • Canada
  • June 1 2016

The 2016 Federal Budget proposed changes to the Income Tax Act (Canada), expected to come into force effective January 1, 2017, that will alter the