Category: Private Company Reorganizations

In the 2018 Federal Budget, the Department of Finance released another chapter in its saga to overhaul how private corporations and their shareholders are taxed. Finance’s initial consultation paper of July 18, 2017 (see our summary here) was met…

“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 decision of the Tax Court in MacDonald earlier this year (2012 TCC 123) has prompted quite a lot of discussion among tax professionals. The case seems to take the debate about the legitimacy of dividend stripping to a new…