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Results: 1-10 of 83

Lipson v. Canada - a sworded tale
  • Cassels Brock & Blackwell LLP
  • Canada
  • February 19 2009

In a split decision rendered in January 2009, the Supreme Court of Canada ("SCC") applied the general anti-avoidance rule under section 245 of the Income Tax Act (Canada) (the "Act") to deny interest deductibility in the highly anticipated Lipson decision


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


Federal Court of Appeal upholds Prévost Car: implications for treaty planning and offshore structures
  • Cassels Brock & Blackwell LLP
  • Canada
  • March 5 2009

The long-awaited recent decision of the Federal Court of Appeal ("FCA") in Prévost Car, 2009 FCA 57, upholds the principle that, in determining the applicable withholding rate on dividends, interest, royalties and other payments to treaty countries such as Holland, Luxembourg and other intermediary jurisdictions with low withholding tax rates, Canada Revenue Agency ("CRA") cannot ignore the intermediary jurisdiction and apply the higher rate that may be applicable had the payment been made directly


Harmonized Sales Tax: amendment to the place of supply rules
  • Cassels Brock & Blackwell LLP
  • Canada
  • April 22 2010

The place of supply rules determine whether suppliers are required to collect the Harmonized Sales Tax ("HST") (i.e. both provincial and federal components) or only the Goods and Services Tax ("GST") on their supplies made in Canada


Nortel update stay extended; Ontario Court of Appeal affirms non-payment of termination and severance
  • Cassels Brock & Blackwell LLP
  • Canada
  • January 26 2010

On January 21, 2010, Mr Justice Morawetz extended the stay of proceedings in the Nortel case to April 23, 2010, and approved a settlement and funding agreement which addressed inter-company issues as between the US and Canadian estates


The harmonization of the GST and the PST in Ontario
  • Cassels Brock & Blackwell LLP
  • Canada
  • February 3 2010

On December 15, 2009, the comprehensive tax reforms announced in the Ontario government's 2009 Budget were enacted into legislation


Canadian income tax primer on mergers and acquisitions
  • Cassels Brock & Blackwell LLP
  • Canada
  • May 14 2010

We have found that there are numerous recurring questions about the Canadian tax considerations applicable to mergers and acquisitions


TD Securities (USA) LLC v. The Queen - Crown does not seek appeal
  • Cassels Brock & Blackwell LLP
  • Canada
  • May 14 2010

As we recently reported, the Tax Court of Canada released its judgment in TD Securities (USA) LLC v. The Queen on April 8, 2010, extending benefits under the Canada-US Income Tax Convention (the "US Treaty") to a limited liability company (the "LLC") established under the laws of the United States


Employee stock options and the 2010 Federal Budget
  • Cassels Brock & Blackwell LLP
  • Canada
  • March 30 2010

The recent 2010 Federal Budget included a number of significant changes to the tax rules under the Income Tax Act (Canada) (the "Act") applicable to employee stock options


TD Securities (USA) LLC v. The Queen - Canada Revenue Agency loses on denying treaty benefits to a LLC
  • Cassels Brock & Blackwell LLP
  • Canada
  • April 19 2010

The Tax Court of Canada recently released its judgment in TD Securities (USA) LLC v. The Queen