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Results: 1-10 of 48

Withholding tax on cross-border commitment fees
  • Cassels Brock & Blackwell LLP
  • Canada
  • July 30 2015

Commitment fees are a common feature of many lending arrangements whereby a lender is given additional compensation above and beyond the stated


Doing business in Canada - a practical guide
  • Cassels Brock & Blackwell LLP
  • Canada
  • November 3 2014

The progressive global liberalization of international trade and investment has generated new opportunities to expand business activities across


Recent developments in Canadian international taxation
  • Cassels Brock & Blackwell LLP
  • Canada
  • June 18 2012

The Canadian federal Department of Finance released the federal budget on March 29, 2012


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


Canada Revenue Agency will no longer automatically back date a voluntary GSTHST registration
  • Cassels Brock & Blackwell LLP
  • Canada
  • February 15 2012

Registration for the GSTHST is mandatory when a person becomes liable to charge and collect the GSTHST as a supplier of goods or services


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"


Flow-through shares: investing in a volatile market
  • Cassels Brock & Blackwell LLP
  • Canada
  • December 1 2008

During a time of market volatility, investors may be reluctant to part with their money; however, there may still be some appetite where tax deductions or credits exist


Glaxosmithkline: transfer pricing law for Canada clarified for cross-border investors
  • Cassels Brock & Blackwell LLP
  • Canada
  • March 9 2011

In the recent Glaxosmithkline transfer pricing case, the Canadian Federal Court of Appeal established a realistic framework for applying the abstract rules promulgated by the OECD, by requiring an analysis of the taxpayer's relevant circumstances, including the legal, financial, commercial, and contractual circumstances that any arm's length person "standing in the shoes of the taxpayer" would face in its economic relations with the relevant cross-border related parties


Federal Budget 2008: compliance relief for cross-border investments
  • Cassels Brock & Blackwell LLP
  • Canada
  • March 31 2008

On February 26, 2008, the Federal government tabled its Budget, in which it proposes a variety of tax changes, including measures to improve the efficiency of the compliance system for non-residents disposing of taxable Canadian property


An overview of Canadian tax credits for non-indigenous film and television production
  • Cassels Brock & Blackwell LLP
  • Canada
  • March 15 2011

Canada, often referred to as "Hollywood North," continues as a leading innovator in the development and implementation of public sector incentives for film and television production