In 2012-0468931C6, the CRA confirmed that the date of disposition for shares sold on a stock exchange is the “settlement date”. When shares are sold on a stock exchange, typically the settlement date is two or three days after…
The following blog was co-written by Greg DelBigio and Leah Plumridge:
The Canada Revenue Agency (“CRA”) now has easier access to confidential taxpayer records as a result of a recent British Columbia Supreme Court decision, Canada Revenue Agency v.…
The following blog was joint collaboration by Greg DelBigio, David Thompson, James Murdoch, and Steve Cook:
Last week saw tax law become the subject of international headlines. Media outlets excitedly announced that as a result of a “leak” of documents the…
“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…
In 2012-0455081I7, the Canada Revenue Agency (CRA) considered costs of constructing a commercial building in circumstances where the land was owned by one company in a corporate group (A Co) and leased to another company in the group (B…
In 2012-0443471E5, the Canada Revenue Agency (CRA) confirmed its position that so-called “tracking shares” are “taxable preferred shares”. The term “tracking shares” (as well as “alphabet shares” and “targeted shares”) has typically been used to describe a special class…
In 2012-0449371I7, the Canada Revenue Agency (CRA) confirmed that a both an upstream and a downstream absorptive merger under US corporate law would qualify for tax-deferred (rollover) treatment under proposed new s. 87(8.2). The facts involved a Canadian company…
On March 21, 2013 the federal government released its budget (http://www.budget.gc.ca/2013/doc/plan/toc-tdm-eng.html).
Mining Industry. The CEE (100%) deduction for intangible mine development expenses will become a CDE (30% per year) deduction, to be fully phased in after calendar 2017. The…
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…