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CRA comments on low-PUC stock dividends and safe income.

Canada - August 1 2017 In 2016-0658351E5 (recently released), the CRA observed that the new rules in s. 55 applicable to low-PUC stock dividends and safe income do not...


CRA says lender-consent fees were not subject to withholding tax.

Canada - July 24 2017 In 2016-0636721I7, a Canadian corporation (Canco) paid fees to existing non-resident lenders for their consent to allow the sale of shares of Canco...


Federal Court of Appeal allows 50 stock-option deduction.

Canada - July 24 2017 In order to benefit from the 50 deduction for stock-option-employment income under s. 110(1)(d), the share acquired on exercise of the option must...


CRA announces arrangement with IRS on country-by-country reports.

Canada, OECD, USA - June 29 2017 On June 7, 2017, the Canada Revenue Agency (CRA) announced an arrangement with the US Internal Revenue Service (IRS) on the exchange of...


CRA updates views on taxable Canadian property look-through rule.

Canada - June 19 2017 A non-resident is taxable in Canada on gains realized on taxable Canadian property (TCP). TCP can potentially include shares of a corporation -...