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Ian Gamble

Thorsteinssons LLP

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Q1 | 2019

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Tax Court says section 16 is not one-sided

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...

Cross-border surplus extraction following arm’s length acquisition was not abusive.

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...

Technical trap for foreign resource properties held by a partnership.

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...

Repsol: Federal Court of Appeal upholds Tax Court’s application of CCA provisions.

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...

CRA says section 143.4 can effectively trump section 80 in debt restructuring.

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...