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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


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


Supreme Court rules that GST debt is unsecured under CCAA
  • Cassels Brock & Blackwell LLP
  • Canada
  • February 2 2011

The Supreme Court of Canada recently ruled in the Century Servicesi case that Goods and Services Tax ("GST") deemed trusts under the federal Excise Tax Act ("ETA") are ineffective in proceedings under the Companies' Creditors Arrangement Act ("CCAA"


Department of Finance announces changes to the tax treatment of stapled securities
  • Cassels Brock & Blackwell LLP
  • Canada
  • July 22 2011

On July 20, 2011 the Department of Finance (“Finance”) announced proposed changes to the Income Tax Act which would effectively deny tax benefits associated with “stapled securities”


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


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


Clean energy tax incentives current and proposed
  • Cassels Brock & Blackwell LLP
  • Canada
  • September 29 2011

Over the last several years, each Federal Budget has proposed a number of tax incentives to encourage clean energy generation and conservation, including gradually expanding the assets that are eligible for an accelerated capital cost allowance and allowing certain intangible project start-up expenses to be treated as “Canadian Renewable and Conservation Expenses” (as defined in the Income Tax Act (Canada) (the “Tax Act”


The Canadian leasing environment: an overview for US professionals (business and legal)
  • Cassels Brock & Blackwell LLP
  • Canada, USA
  • May 5 2011

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


Supreme Court of Canada grants leave in tax case involving contingent liabilities
  • Cassels Brock & Blackwell LLP
  • Canada
  • July 4 2012

In a rare oral hearing, the Supreme Court of Canada granted leave in the case of Daishowa-Marubeni International Ltd. v. The Queen


Ontario adopts new wealth tax
  • Cassels Brock & Blackwell LLP
  • Canada
  • June 25 2012

On June 20, 2012, Ontario’s legislature passed a bill that introduces a 2 tax increase on the taxable income of individuals in excess of $500,000