In Kruger Incorporated v. Her Majesty the Queen (2015 TCC 119) the Tax Court of Canada concluded that, for the purposes of computing taxable income, the taxpayer could not value its foreign exchange option contracts on a mark to market…
In Re Pallen Trust, 2015 BCCA 222, a corporation paid a dividend to a discretionary trust on the assumption that subsection 75(2) of the Income Tax Act would attribute the income to the corporation. At the time, the general understanding…
The CRA cancelled IT-90 and released a new Income Tax Folio outlining the factors relevant to determining whether a partnership exists: “What is a partnership?” (S4-F16-C1). Comments from the public will be accepted until August 5, 2015.
In Mac’s Convenience Stores Inc. v. Canada, 2015 QCCA 837, the Quebec Court of Appeal upheld the decision of the Superior Court refusing to allow rectification of a $136 million dividend that caused adverse tax consequences the company’s tax…
Parliament has passed the government’s controversial Bill C-51, enacting the Security of Canada Information Sharing Act. A related amendment to subsections 241(9) and (10) of the Income Tax Act gives CRA officials the power to share taxpayer information with…
The CRA released a compilation of its positions on interest deductibility under paragraph 20(1)(c) and other provisions in a new Income Tax Folio, “Interest Deductibility” (S3-F6-C1), which cancels IT-533. Comments from the public will be accepted until June 6,…
The filing deadline for 2014 tax returns has been extended from April 30, 2015 to May 5, 2015. The CRA released a communication in error on April 24, 2015 referring to the May 5 deadline. To avoid any confusion, the…
In today’s provincial budget Ontario announced that it has eliminated the Ontario Resource Tax Credit and the Additional Tax on Crown Royalties. The Ontario Resource Tax Credit was generally viewed as beneficial for mining companies because it typically provided a…
Minister of Finance Joe Oliver announced as part of the 2015 federal budget released on April 21, 2015 that the annual contribution limit for Tax-Free Savings Accounts will be increased from $5,500 to $10,000 effective for contributions made in the…
Alberta released its 2015 budget yesterday, which includes several tax measures, including two new tax brackets starting in 2016 for incomes over $100,000 and $250,000, respectively. Here is a link to Alberta Fiscal Plan: http://finance.alberta.ca/publications/budget/budget2015/fiscal-plan-complete.pdf.