Ian Gamble has been selected for inclusion in Best Lawyers in Canada in the practice area of Tax Law. Ian has also been listed in the Guide to the World’s Leading Tax Advisers and has previously been noted as among the Top 10 tax advisors in Canada by the International Tax Review. Read complete profile »
On September 13, 2013 the Department of Finance released significant draft legislative proposals. The attached Quick Update Report outlines the corporate tax-related items in this release, which
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In 2013-0474671E5, the CRA concluded that “the simple holding of shares” by a US company is not a business activity, and as such, would be ignored when applying the “more closely connected business activities” exception in the new “foreign…
The CRA recently released three tax interpretations relating to the mining industry.
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In 2013-0487871I7, the CRA rulings directorate advised a local CRA office that certain tax elections filed with the taxpayer’s original tax return should not be considered as late-filed, even though the tax return itself was late-filed. Various provisions require…
In 2010-0387631I7 (released September 25, 2013), the CRA’s head office advised a local tax services office that the general anti-avoidance rule could be used, in some cases, to convert a tax-free dividend on foreign affiliate shares into a taxable…
In Envision Credit Union v. The Queen, 2013 SCC 48, the Supreme Court of Canada (SCC) held that parties to an amalgamation could not legally contract out of the automatic consequences of an amalgamation under the applicable corporate statute,…
In The Queen v. PwC as Trustee in Bankruptcy for Bioartificial Gel Technologies (Bagtech) Inc., 2013 FCA 164 (Bagtech), the Federal Court of Appeal (FCA) confirmed the full scope of the Supreme Court of Canada’s decision in Duha Printers…
In 2012-0441771R3 (released September 18, 2013), the CRA ruled that an exploration program underneath the site of a former open pit mine would qualify as “Canadian exploration expenses” (CEE) notwithstanding that a former mine at the site had previously…
In 2013-0491061R3, the CRA ruled that a Canadian company’s repayment of upstream loans, followed by the sale of an entire foreign affiliate group to the foreign parent company, would be considered a bona fide repayment and not part of…
In 2012-0463611R3 (released September 18, 2013), the CRA ruled on a divisive reorganization of a particular foreign affiliate (FA 1) into two foreign affiliates (Newco and FA 1). The purpose was to consolidate existing loans (FA Loans) made by…