Category: Corporate Reorganizations

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 trial decision at the Tax Court of Canada (2016 TCC 159). The judgment contained several…

“Rectification”, a means to “fix” a mistake made in the implementation of an agreement, has been a popular topic in tax law since the Supreme Court of Canada’s decisions limiting the availability of rectification for tax planning errors in AG…

The so-called “anti-surplus stripping rule” in section 84.1 of the Income Tax Act (Canada) can apply where an individual taxpayer transfers shares of a corporation to another corporation with which the taxpayer does not deal at arm’s length.  If the…