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Salvador M. Borraccia

Baker McKenzie

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Canada’s 2010 Budget international tax changes

Canada - March 12 2010 Foreign investors, particularly private equity funds, have expressed frustration with the complexity of the reporting requirements under section 116 of the Canadian Income Tax Act (the Act) with respect to the disposition of investments in taxable Canadian property (TCP) such as shares of Canadian companies that are not listed on a stock exchange....

Brian D. Segal, James R. Sennema, Kristy J. Balkwill.


Canadian changes to taxation of stock options

Canada - March 12 2010 An employee who exercises a stock option is generally required to include in employment income a taxable benefit equal to the difference between the fair market value of the shares on the date of acquisition and the exercise price paid by the employee....

Brian D. Segal, James R. Sennema, Kristy J. Balkwill.


Tax Court of Canada issues ruling on GE Capital Canada guarantee fee

Canada - January 8 2010 On December 4, 2009 the Tax Court of Canada released its decision in GE Capital Canada Inc. v. Her Majesty the Queen....

Brian D. Segal, Christopher S. Raybould.


New related party transaction reporting requirements in Canada

Canada - May 21 2009 On December 22, 2008 the Canada Revenue Agency ("CRA") released a new version of the information reporting form T106 that includes significantly expanded levels of detail for disclosures of related party transactions....

Christopher S. Raybould.