In February 2013, the OECD issued its report addressing “base erosion and profit shifting” (BEPS) by multinational enterprises: see my quick update at http://thor.ca/blog/2013/02/finance-embraces-oecds-report-on-base-erosion-and-profit-shifting/. On July 19, 2013, the OECD released its Action Plan for this ambitious project (see…
In his Blog posting “Finance Releases Proposed Amendments” (15 July 2013), my colleague Ian Gamble discussed several of the legislative proposals recently made by the Minister of Finance.
The proposals also include suggested amendments to s.241 of the Income Tax Act…
On July 12, 2013 Finance released several proposed amendments (see http://www.fin.gc.ca/drleg-apl/Itedst-irdatv-0713-eng.asp). The following is a quick summary of selected items, which is not intended to be exhaustive.
- Functional currency tax reporting. A change is being made to s.
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In Industries Perron Inc. v. The Queen, 2013 FCA 176, the Federal Court of Appeal (FCA) disallowed a deduction for amounts deposited to secure potential US softwood countervailing or anti-dumping duties. Under s. 20(1)(vv) a specific deduction is available for…
Forgive me for saying this about a government publication, but Canada’s Taxpayer Bill of Rights (TBR) really is a misleading document. It styles itself as a “Bill of Rights,” but it can’t be enforced in any legal way. The recent…
An immediate deduction is available for contributions to an environmental trust that is established for the sole purpose of funding the reclamation of a qualifying site (s. 20(1)(ss) and s. 211.6). In 2012-0463471R3 (released last week), the Rulings Directorate…
In 2012-0461741E5 (released last week), the Rulings Directorate applied s. 88(1)(d)(ii) to restrict a Canadian parent company’s (Canco’s) ability to increase the tax cost of capital property Canco received on the liquidation of its Canadian subsidiary (Target). The situation…
In 2012-0464901I7 (released last week), the Rulings Directorate concluded that the “substituted share” concept, contained in proposed new s. 93(2.01) and existing s. 93(2), could apply to any sequence of property substitutions even if the property substituted within the…