Tax Alert Archives February 2014

Draft Legislation Relating to Taxation of Canadian Banks with Foreign Affiliates Released

Yesterday, the Department of Finance released draft legislative amendments to the Income Tax Act (Canada) and the Income Tax Regulations relating to the taxation of Canadian banks with foreign affiliates. The new proposals contain modifications to those released for consultation…

Prepared by: Alexander Demner

Alexander is a partner practicing in the firm’s Vancouver office. Alexander’s practice covers several areas of taxation, including owner-manager remuneration, estate planning, pre-sale and divestiture structuring, and taxpayer representation (both at the administrative appeal stage and in front of the… more »

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CRA Announces Transitional Measures for T1135 Filing Requirements

The Canada Revenue Agency (CRA) announced today transitional rules in respect of the specified foreign property reporting form (T1135), a new version of which was released in June of 2013. The new T1135 asks for considerable more detail than its…

Prepared by: Alexander Demner

Alexander is a partner practicing in the firm’s Vancouver office. Alexander’s practice covers several areas of taxation, including owner-manager remuneration, estate planning, pre-sale and divestiture structuring, and taxpayer representation (both at the administrative appeal stage and in front of the… more »

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FCA Clarifies Application of Section 174

In Canada v. ACI Properties Ltd., 2014 FCA 45, the Federal Court of Appeal clarified the application of section 174 of the Income Tax Act (Canada), which allows the Minister to ask the Court for a binding determination of a…

Prepared by: Alexander Demner

Alexander is a partner practicing in the firm’s Vancouver office. Alexander’s practice covers several areas of taxation, including owner-manager remuneration, estate planning, pre-sale and divestiture structuring, and taxpayer representation (both at the administrative appeal stage and in front of the… more »

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Deadline for 2013 RRSP Contributions – March 3, 2014

A reminder that RRSP contributions must be made by March 3, 2014 to be deducted against 2013 income. As the normal deadline of March 1st falls on a Saturday, the time limit was extended until the following Monday. More information…

Prepared by: Alexander Demner

Alexander is a partner practicing in the firm’s Vancouver office. Alexander’s practice covers several areas of taxation, including owner-manager remuneration, estate planning, pre-sale and divestiture structuring, and taxpayer representation (both at the administrative appeal stage and in front of the… more »

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2014 B.C. Budget Released

British Columbia’s Minister of Finance, the Honourable Michael de Jong, presented the B.C. government’s 2014 Budget today in the provincial legislature. Among other tax measures, the Budget announced the government’s intention to levy a new income tax on liquefaction at…

Prepared by: Alexander Demner

Alexander is a partner practicing in the firm’s Vancouver office. Alexander’s practice covers several areas of taxation, including owner-manager remuneration, estate planning, pre-sale and divestiture structuring, and taxpayer representation (both at the administrative appeal stage and in front of the… more »

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Tax Court Grants Huge Costs Award to Taxpayers

In a recent decision, Justice Boyle of the TCC awarded a staggering $410,000 cost award to a group of taxpayers who were successful at trial. Boyle J. stated that the importance and complexity of the issues under review (including whether…

Prepared by: Alexander Demner

Alexander is a partner practicing in the firm’s Vancouver office. Alexander’s practice covers several areas of taxation, including owner-manager remuneration, estate planning, pre-sale and divestiture structuring, and taxpayer representation (both at the administrative appeal stage and in front of the… more »

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2014 Federal Budget Released

The federal government tabled its 2014-2015 Budget in Parliament today. The budget contains a number of proposals designed to “close tax loopholes and improve the fairness and integrity of the tax system.”  A full copy of the budget materials can…

Prepared by: Alexander Demner

Alexander is a partner practicing in the firm’s Vancouver office. Alexander’s practice covers several areas of taxation, including owner-manager remuneration, estate planning, pre-sale and divestiture structuring, and taxpayer representation (both at the administrative appeal stage and in front of the… more »

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CRA Launches New SR&ED Tool and Service

The Canada Revenue Agency has announced the launch of the Self-Assessment Learning Tool (SALT) and the First-Time Claimant Advisory Service (FTCAS) in order to assist potential claimants understand the Scientific Research and Experimental Development (SR&ED) program. SALT is an online…

Prepared by: Alexander Demner

Alexander is a partner practicing in the firm’s Vancouver office. Alexander’s practice covers several areas of taxation, including owner-manager remuneration, estate planning, pre-sale and divestiture structuring, and taxpayer representation (both at the administrative appeal stage and in front of the… more »

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Canada and U.S. Reach Agreement on Foreign Account Tax Compliance Act

On February 5, 2014, the Canadian government announced that Canada and the United States have signed an intergovernmental agreement under the Canada-U.S. Tax Convention respecting the scope and application of the Foreign Account Tax Compliance Act (FACTA). Amongst other things,…

Prepared by: Alexander Demner

Alexander is a partner practicing in the firm’s Vancouver office. Alexander’s practice covers several areas of taxation, including owner-manager remuneration, estate planning, pre-sale and divestiture structuring, and taxpayer representation (both at the administrative appeal stage and in front of the… more »

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