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Results: 1-10 of 86

The Queen v. Landrus: GAAR will not plug the holes in existing anti-avoidance rules
  • Cassels Brock & Blackwell LLP
  • Canada
  • June 5 2009

Earlier this year, the Supreme Court of Canada released its landmark general anti-avoidance rule ("GAAR") decision in Lipson v. The Queen ("Lipson"


UPS vs. Sentinel Hill: new Supreme Court authority for returning overpaid tax to the payor
  • Cassels Brock & Blackwell LLP
  • Canada
  • June 5 2009

It was not that long ago that the Ontario Court of Appeal released an unsettling decision concerning overpaid withholding tax under Part XIII of the Income Tax Act (Canada


Bermuda to sign tax information exchange agreement with Canada
  • Cassels Brock & Blackwell LLP
  • Bermuda, Canada
  • June 15 2009

On May 7, 2009, Bermuda's Ministry of Finance announced that it will be signing a bilateral tax information exchange agreement ("TIEA") with Canada


Ontario increases its film and television production services tax credit
  • Cassels Brock & Blackwell LLP
  • Canada
  • July 2 2009

In order to maintain Ontario's competitive position as a location of choice for foreign film and television producers, the Ontario Government has just announced a series of proposed amendments to the Ontario Production Services Tax Credit (the "OPSTC") program that will increase the refundable OPSTC from its current level of 25 of qualifying labour expenses to 25 of all qualifying expenses incurred in the Province of Ontario


Wabush Iron Company Limited v. The Queen drafting really matters
  • Cassels Brock & Blackwell LLP
  • Canada
  • September 14 2009

The decision in Wabush Iron Company Limited v. The Queen, 2009 DTC 1157 (Tax Court of Canada), which confirmed a substantial assessment by the Canada Revenue Agency (“CRA”), was based on an interpretation of a supply agreement


The Canadian equipment finance environment: an overview for European professionals
  • Cassels Brock & Blackwell LLP
  • Canada
  • October 5 2009

As international trade grows, financial institutions and manufacturers of equipment recognize that international sales or the globalization of their business is a requirement to staying competitive


Changes to Canada’s Income Tax Act and impact on equipment finance
  • Cassels Brock & Blackwell LLP
  • Canada
  • May 4 2009

On January 1, 2008, the Canadian government amended the Income Tax Act (Canada) to eliminate withholding taxes on interest payments for arm’s length loan transactions so long as the interest payments are not dependent or computed by reference to revenue, profit, cash flow, commodity price or any similar criteria ("Participating Debt"


The end of Prévost Car not the end of the story
  • Cassels Brock & Blackwell LLP
  • Canada
  • June 10 2009

The Crown has confirmed that the decision of the Federal Court of Appeal ("FCA") in Prévost Car, 2009 FCA 57, will not be appealed


Update on Canadian unlimited liability companies
  • Cassels Brock & Blackwell LLP
  • Canada, USA
  • November 27 2009

The Fifth Protocol to the Canada-US Tax Convention (the "Treaty") introduced significant changes which may adversely affect the use of "reverse hybrid" and "hybrid" entities, including unlimited liability companies ("ULCs"


Comparing US and Canadian rules for debt forgiveness
  • Cassels Brock & Blackwell LLP
  • Canada, USA
  • October 29 2009

In the current recession, some North American businesses facing difficulty in meeting their debt obligations may consider the implications of restructuring their debt in Canada or the US