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...
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...
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...
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...
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 -...
