Searching Content indexed under Tax by Bill Maclagan ordered by Published Date Descending.
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What The New Speculation And Vacancy Tax Act Means For B.C. Real Estate
British Columbia's Speculation and Vacancy Tax Act (Bill 45) (SVTA) recently received royal assent.
10 Jan 2019
Tax Court Suggests CRA Be More Responsible In Evaluating Diligence Defences
The recent decision in Home Depot of Canada Inc. v. Her Majesty the Queen dealt with the common law defence of due diligence, as opposed to one of the statutory defences available to directors under subsection 323(3) of the Excise Tax Act (the ETA) or subsection 227.1(3) of the Income Tax Act.
2 Sep 2009
Technical Explanation Clarifies Impact Of The Fifth Protocol On Employees
Amendments to Article XV of the Canada-United States Income Tax Convention (the Treaty) appear to expand the circumstances in which Canada and the U.S. may tax each otherís residents who exercise employment in the other Contracting State.
18 Jul 2008
Armís Length And Back-To-Back Loans
One of the critical elements in complying with the 5/25 exemption is that the borrower and lender must act at armís length at the time an interest payment is made. Whether or not parties act at armís length is a mixed question of law and fact. Related persons are deemed not to deal at armís length. It is a question of fact whether other persons deal at armís length.
1 Jun 2005
Canada Enhances Tax Incentives For Green Energy Projects
For a number of years, Canada has offered tax incentives to encourage the development of efficient or so-called Green Energy Projects. These incentives include an accelerated capital cost allowance deduction for the capital cost of certain assets and an immediate deduction for certain expenses incurred in the development of Green Energy Projects.
3 Mar 2005
Application Of Treaty Benefits To Partnerships
In Canada, dividends, interest, royalties and certain other payments paid to non-residents are subject to 25% withholding tax on the gross amount pursuant to the Income Tax Act (Canada) (the Act). Under most of Canadaís tax treaties, including the Canada-U.S. Tax Convention (the US Treaty) and the Canada-U.K. Tax Convention (the UK Treaty), the withholding rate is reduced on payments to persons who are residents of the U. S. or the U.K., respectively for purposes of the US Treaty or the U
7 Dec 2004
Solving Non-Compliance Through Voluntary Disclosure
The Income Tax Act (Canada) (the Act) imposes a variety of technical rules, filing requirements and reporting requirements. Failure to comply can lead to interest charges, penalties and, potentially, criminal sanctions.
25 Feb 2004
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