“The Government will monitor developments in this area and, if structures or transactions emerge that undermine the effectiveness of the measure, evaluate whether further action is warranted, with possible retrospective application.” (My emphasis.)
“The Government will…
The 2013 federal budget continues the trend of removing income tax incentives for Canadian mining companies. In particular, the budget proposes to reduce the deductions available to mining companies in respect of expenses incurred in developing or expanding mines.
The…
Two important features of the 2013 Budget, released last week, are the closing of tax “loopholes” used for “aggressive” tax planning and renewed focus upon measures to investigate and prosecute tax evasion.
In the words of the government:
“To help…
The federal budget last week (March 21) provoked the usual range of comment and criticism from the media, members of the opposition parties, and the blogosphere. I read very little discussion of the traditional idea that budgetary proposals are to…
I was on an airplane last week in order to escape from the interminable Vancouver rain. As I contemplated the warmer and drier climate that would receive me, I also used the flight as a chance to catch up on…
In Anchor Pointe Energy Ltd. v. the Queen, 2007 FCA 188 the Court held “[i]t is trite law that, barring exceptions, the initial onus of proof with respect to assumptions of fact made by the Minister in assessing a taxpayer’s…
A recent decision of the Tax Court is at times interesting, surprising and disturbing. The case – Swirsky v R, 2013 TCC 73 – raises an important question about the scope of paragraph 20(1)(c) of the Income Tax Act. That…
A recent newspaper article described a criminal prosecution commenced by the United States against a Swiss Bank. The charge alleged that the bank provided secret bank accounts to US citizens for the purpose of assisting those account holders in the…
There’s been a lot in the news recently about appropriate responses to tax avoidance schemes. The OECD has just released a report on tax base erosion and profit shifting (February, 2013) which was endorsed by the G-20 Finance Ministers in…
In my January 8, 2013 post (“My Name is Cliff, Drop Over Some Time”), I criticized parliamentarians for passing most tax legislation without much, if anything, in the way of informed debate. As a consequence, there is a lot of…