We use cookies to customise content for your subscription and for analytics.
If you continue to browse Lexology, we will assume that you are happy to receive all our cookies. For further information please read our Cookie Policy.

Search results

Order by: most recent most popular relevance



Results: 1-10 of 568

CBACPA Joint Committee on Taxation - Submissions on Voluntary Disclosure Program
  • Thorsteinssons LLP
  • Canada
  • August 17 2017

Following the CRA’s release of Draft Information Circular IC00-1R6 proposing drastic changes to the Voluntary Disclosure Program, the Joint Committee


Taxpayer Beware: Courts May Choose to Ignore a CRA Administrative Concession
  • Thorsteinssons LLP
  • Canada
  • August 14 2017

Taxpayers regularly argue that an administrative policy adopted by the Canada Revenue Agency (the “CRA”) constitutes an incorrect interpretation of


The Tax Court disapproves of taking questions “under advisement” in examinations for discovery
  • Thorsteinssons LLP
  • Canada
  • August 10 2017

In Burlington Resources Finance Company v. The Queen, 2017 TCC 144, Madam Justice D’Auray considered a motion brought by the Crown to compel the


CRA comments on low-PUC stock dividends and safe income.
  • Thorsteinssons LLP
  • 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


CRA says lender-consent fees were not subject to withholding tax.
  • Thorsteinssons LLP
  • 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


Federal Court of Appeal allows 50 stock-option deduction.
  • Thorsteinssons LLP
  • 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


Federal Court of Appeal considers availability of rectification
  • Thorsteinssons LLP
  • Canada
  • July 21 2017

Rectification has been a popular topic in tax law since last year's Supreme Court decisions limiting its availability for tax planning errors


Finance Proposes Substantial Changes to Private Corporation Taxation
  • Thorsteinssons LLP
  • Canada
  • July 20 2017

On July 18, 2017, the Department of Finance released its consultation policy paper on the taxation of private corporations first announced in Budget


Finance Minister Releases Consultation Paper “Tax Planning Using Private Corporations”
  • Thorsteinssons LLP
  • Canada
  • July 19 2017

Finance Minister Bill Morneau has released a consultation paper on certain tax planning strategies that involve the use of private corporations. The


Partial Indemnity Cost Award to Taxpayer Who Was Partly Successful in Valuation Case
  • Thorsteinssons LLP
  • Canada
  • July 13 2017

In Grimes v. The Queen, the Tax Court of Canada recently awarded costs above the Tariff to a taxpayer who was partly successful in an appeal turning