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Searching Content indexed under Tax Treaties by Borden Ladner Gervais LLP ordered by Published Date Descending.
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Commercial Realities Shape The Interpretation Of Tax Treaties
In a recent decision, the Tax Court of Canada considered CRA's own prior statements as well as the commercial realities of resource companies in finding that treaty benefits applied to a Luxembourg corporation.
Canada
13 Sep 2018
2
Budget fédéral 2018 : Équité et classe moyenne toujours dans la mire
L'honorable William Morneau, ministre des Finances, a déposé le budget fédéral 2018 du gouvernement (le « budget 2018 ») le 27 février 2018 (le « jour du budget »).
Canada
1 Mar 2018
3
Federal Budget 2017 — A Focus On Innovation And Tax Fairness For The Middle Class
The Honourable William Morneau, Minister of Finance, tabled the Government's 2017 Federal Budget on March 22, 2017.
Canada
23 Mar 2017
4
Canada To Unilaterally Override All Tax Treaties With New Anti-Treaty Shopping Rule
International tax avoidance has received considerable attention over the past few years.
Canada
7 Mar 2014
5
Supreme Court Of Canada Dismisses Leave To Appeal In Prescient Foundation
The application for leave to appeal the Federal Court of Appeal’s decision in Prescient Foundation v Minister of National Revenue was dismissed by the Supreme Court of Canada ("SCC") with costs on November 28, 2013.
Canada
3 Dec 2013
6
Latest Step In CRA's New Audit Approach: "Risk Assessment" Interviews With Large Businesses
In the next few weeks, the Canada Revenue Agency ("CRA") plans to conduct individual risk-assessment interviews with a select group of 50 large businesses.
Canada
21 Feb 2012
7
Canada's Supreme Court To Hear GAAR Appeal
The concept of paid-up capital is important for Canadian tax purposes in that, unlike certain of its treaty partners, Canada permits corporations to return capital to shareholders (even if they have accumulated earnings and profits for tax purposes), without payment of Canadian non-resident withholding tax.
Canada
10 Feb 2010
8
Canadian Government Acts To Restore Interest Deduction For Canadian Businesses Investing Abroad.
The Minister of Finance for Canada - the Honourable James Flaherty - tabled the Conservative Government's federal Budget 2009 titled "Canada's Economic Action Plan" at 4:00 p.m. this afternoon.
Canada
28 Jan 2009
9
Canada Tax: 2008 In Review
The Canadian economy was impacted in 2008 by the global economic crisis. Canadian stock markets and the Canadian dollar experienced severe volatility, influenced by swings in commodity prices (including particularly the price of oil).
Canada
27 Jan 2009
10
Advisory Panel Delivers Final Report
On December 10, 2008, the Advisory Panel on Canada’s System of International Taxation delivered its lengthy final report and recommendations for change to the Canadian Minister of Finance.
Canada
15 Dec 2008
11
Canada Reviews International Tax System
On April 25, 2008, the Advisory Panel established by the Canadian Government following on the 2007 Budget initiative to study Canada’s international tax system and make recommendations for change, issued its first report in the form of a Consultation Paper entitled "Enhancing Canada’s International Tax Advantage.
Canada
28 Apr 2008
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