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Results: 1-10 of 593

Tax Loss Transactions Denied
  • Thorsteinssons LLP
  • Canada
  • January 4 2018

The Tax Court of Canada recently decided a new case under the general anti-avoidance rule (“GAAR”) in section 245 of the Income Tax Act. In Birchcliff


Revised Income Splitting Rules and Guidance
  • Thorsteinssons LLP
  • Canada
  • December 13 2017

The Department of Finance has released revised draft legislation and background information on its proposals to prevent income splitting. The


OECD approves the 2017 update to the OECD Model Tax Convention
  • Thorsteinssons LLP
  • OECD, Canada
  • November 27 2017

On November 21, 2017, the OECD Council approved the contents of the 2017 Update to the OECD Model Tax Convention. The 2017 Update primarily comprises


Will Vancouver home buyers be on the hook for a seller’s vacancy tax liability?
  • Thorsteinssons LLP
  • Canada
  • November 24 2017

If you thought Vancouver’s vacancy tax (or “empty homes tax”) was a problem only for absentee condo owners, think again. A flaw in the scheme of the


Parliamentary Budget Officer (PBO) Releases Report on Proposed Changes to Passive Investment Income
  • Thorsteinssons LLP
  • Canada
  • November 24 2017

On November 23, 2017, the PBO released its analysis estimating the potential fiscal magnitude of changes to passive income taxation based on Finance


Auditor General of Canada Releases 2017 Fall Report
  • Thorsteinssons LLP
  • Canada
  • November 22 2017

On November 21, 2017, the Auditor General released its Fall Report containing the results of 6 audits completed since the summer, including an audit


Federal Court of Appeal releases decision on application of GAAR rule
  • Thorsteinssons LLP
  • Canada
  • November 17 2017

On October 13 2017 the Federal Court of Appeal released its decision in Univar Holdco Canada ULC v HMQ (2017 FCA 207), overturning the Tax Court's


Government of Canada Announces Consultation on Proposed Excise Duty Framework for Cannabis Products
  • Thorsteinssons LLP
  • Canada
  • November 14 2017

On November 10, 2017, the Department of Finance released proposed legislation concerning an excise duty framework for cannabis products for comment


Federal Court of Appeal Releases it decision on Univar Holdco Canada ULC. v. H.M.Q. 2017 FCA 207
  • Thorsteinssons LLP
  • Canada
  • November 2 2017

On October 13, 2017, the Federal Court of Appeal released its decision in Univar Holdco Canada ULC. v. H.M.Q. 2017 FCA 207 (“Univar”), overturning the


Tax Court says section 16 is not one-sided
  • Thorsteinssons LLP
  • 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