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Supreme Court of Canada Bulletin - December 14, 2017
  • Gowling WLG
  • USA, Canada
  • December 14 2017

On appeal from a judgment of the British Columbia Court of Appeal (2016 BCCA 200), setting aside in part a decision of Brown J. (2015 BCSC 1170


Unsuccessful interest relief application
  • Gowling WLG
  • Canada
  • June 6 2017

Relief from interest accrual requested under the Income Tax Act (Canada) (“ITA”) in a complex and protracted dispute was recently rejected in Walsh v


Foreign exchange gains on debt-parking
  • Gowling WLG
  • Canada
  • August 30 2016

New rules have been proposed that would require accrued foreign exchange gains on a foreign currency debt to be realized when the debt becomes a


Sales of linked notes
  • Gowling WLG
  • Canada
  • August 12 2016

In Budget 2016, the Department of Finance continued its quest to eliminate investment products that have ‘character conversion’ features (those that


Ontario land transfer tax retroactive amendment to de minimus relief
  • Gowling WLG
  • Canada
  • August 4 2016

The Ontario Government began to tax beneficial transfers of real property in Ontario under the Land Transfer Tax Act on July 19, 1989. The objective


Loss of incentives for performance held to offend section 8 of the Interest Act: Supreme Court of Canada
  • Gowling WLG
  • Canada
  • June 29 2016

In two earlier editions of Fully Secured (March 2015 and September 2015; Volume 6, Nos. 1 and 3), we reported on the lower court and Alberta Court


Thirty per cent rule update and tax policy review
  • Gowling WLG
  • Canada
  • June 13 2016

The federal government is reviewing one of the investment rules that applies to registered pension plan investments. The review is considering both


Appeals allowed - 6 May 2016
  • Gowling WLG
  • Canada
  • May 6 2016

On appeal from a judgment of the Alberta Court of Appeal (2014 ABCA 234), affirming a decision of Romaine J. (2012 ABQB 411), which set aside a


Canada’s new tax treaty with Taiwan: 10 key aspects
  • Gowling WLG
  • Taiwan, Canada
  • March 15 2016

On Jan. 15, 2016, after 16 years of negotiations, the Trade and Economic Offices of Canada and Taiwan signed a tax arrangement (the "Treaty"). The


Interest deductibility: recent developments
  • Gowling WLG
  • Canada
  • June 30 2015

The Canadian tax regime generally allows for the deductibility of interest on borrowed money or indebtedness incurred for the purposes of earning