François Barette
Fasken
Articles
Payments to relinquish right to reinstatement likely taxable according to CRA
Canada - December 8 2011 In CRA Document No.: 2011-0421931E5, the Canada Revenue Agency (the "CRA") concluded that a payment made by an employer to relinquish an employee's potential right to reinstatement likely constituted a "retiring allowance," as defined in the Income Tax Act (Canada) (the "Act") and would, therefore, be taxable.
The True Intention of the Parties Has Its Limits: An Important Reminder from the Supreme Court of Canada
Canada - December 13 2016 Following its 2013 AES decision, the Supreme Court of Canada ("SCC") has once again addressed the issue of retroactive modifications to written…
Incorporation for Real Estate Professionals
Canada - February 9 2021 Accountants, engineers, lawyers, doctors, dentists. Now real estate professionals join the Ontario regulated professionals who are able to personally…
Alain Ranger, Claude E. Jodoin, Nicolas Simard, Christopher Steeves, Kevin H. Yip
GlaxoSmithKline transfer pricing case heads to Supreme Court
Canada - March 25 2011 The Supreme Court of Canada has just granted leave to appeal and cross-appeal in the GlaxoSmithKline transfer pricing case.
Crown loses GE Capital Canada transfer pricing appeal
Canada - December 21 2010 The Federal Court of Appeal (FCA) has dismissed the Crown's appeal in the GE Capital Canada transfer pricing case.
