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Surplus stripping: is the pipeline leaking again?

Canada - August 23 2013 On April 25, 2013, the Federal Court of Appeal ("FCA") released its decision in the case of MacDonald v. R (2013 FCA 110) ("MacDonald")...

William J. Fowlis.

Canada Revenue Agency eliminates tax deferral for joint ventures

Canada - June 13 2012 CRA has announced that it is withdrawing its administrative position allowing participants in a joint venture (“JV”) to establish a fiscal period for the JV that differs from the fiscal periods of the JV participants....

Good plan went bad

Canada - June 6 2012 The British Columbia case of Botham Holdings Ltd. (Trustee of) v. Braydon Investments Ltd. is a reminder that tax and estate plans must take non-tax issues and law into account....

Sale of business restrictive covenants

Canada - December 1 2011 On October 7th, 2003 the Federal Minister of Finance announced that the Income Tax Act would be amended to tax payments in respect of restrictive covenants....

Nathalie Marchand.

Transfer of charitable donation tax credits

Canada - February 10 2011 The Canada Revenue Agency ("CRA") has extended its administrative position with respect to the transfer of donation tax credits from one spouse or common law partner to the other....