Just about everyone with an email account has received at least one of these: a letter from a far off place (often in Africa) promising a very substantial reward if the recipient will provide the financing required to free up…
Transfer pricing issues arise when entities of a multinational corporation resident in different jurisdictions transfer property or provide services to one another. During the week of October 15, 2012, the Supreme Court of Canada decided that any transfer pricing reassessment…
During the week of October 15, 2012, the Federal Court of Appeal (FCA) applied Canada’s general anti-avoidance rule (GAAR) to deny a capital loss that was “a loss on paper only in the sense that no economic loss was suffered”…
In its October 15, 2012 release of updated draft legislation (at http://www.fin.gc.ca/drleg-apl/bia-leb-1012-eng.asp), Finance eliminated the benefit of the new outbound financing rule for Canadian subsidiaries of foreign multinational corporations if a treaty applies to reduce the Canadian company’s interest…
Advocates of the plain meaning approach to statutory interpretation (I’m one of them) argue that clear and unambiguous words in the Act should be applied as written, however much the CRA dislikes the result. Applying the plain words sometimes conflicts…
The following blog was co-written by Greg DelBigio and Natasha Reid:
In a presentation made to members of the Canadian Bar Association Tax Subsection in November of 2011, the CRA provided statistics and information on the application of third-party advisor…
In correspondence released October 10, 2012 (2012-0455781E5), the CRA said it has the power to reassess a dissolved Ontario company. This stems from s. 242(1)(b) of the Business Corporations Act (Ontario), which provides that a civil, criminal, or administrative action…
One of the simplest business structures involves one party (typically a company) holding legal title for and on behalf of the true beneficial owner (in a group). This can be done for various reasons, both tax and non-tax related. The…
An appeal to the Tax Court from an assessment must be filed within specific time limits. As a general rule, the notice of appeal must be filed within 90 days of receiving the Minister’s notification confirming the assessment. Subsection 165(3)…
There are various reasons why an individual might decide to give up residence in Canada; most of them are not tax driven. Canada’s tax rates are favourable compared to those in most developed countries and changes in family circumstances and…