Canada - October 23 2017
Section 16 of the Income Tax Act (Canada) provides that "Where, under a contract or other arrangement, an amount can reasonably be regarded as being...
Canada - October 16 2017
Canada's general anti-avoidance rule (the GAAR) in s. 245 of the Income Tax Act is, in the final analysis, an anti-abuse rule. Even if a transaction...
Canada - October 11 2017
Consider a case in which a foreign resource business is carried on through a limited partnership, and the partnership disposes of a foreign resource...
Canada - October 3 2017
In The Queen v. Repsol Canada Ltd. et. al., 2017 FCA 193, the Federal Court of Appeal (FCA) upheld the Tax Court of Canada's decision to include in...
Canada - September 25 2017
In 2016-0628741I7, CRA headquarters was asked by a CRA tax services office whether s. 143.4 would apply in respect of a debt-restructuring plan (the...
