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Searching Content indexed under Income Tax by Cassels Brock ordered by Published Date Descending.
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1
CRA Announces Proposed Changes To The Voluntary Disclosure Program
In June 2017, the Canada Revenue Agency released its proposed changes to the voluntary disclosure program relating to income tax, excise tax, GST/HST and excise duties (Taxes).
Canada
5 Jul 2017
2
Non-Resident Private Equity Investors And Management Fees - Some Canadian Tax Considerations
Typically in the case where a non-resident private equity group (Non-Resident Group) acquires a Canadian target (Canco), the Non-Resident Group provides management services to Canco...
Canada
26 Apr 2017
3
Canadian Federal Income Tax Considerations Applicable In Respect Of "Secondary" Transactions
This article summarizes the principal Canadian federal income tax considerations generally applicable in respect of a "secondary" sale of an interest in a limited partnership (LP Interest).
Canada
26 Apr 2017
4
CRA Releases New Guidelines On CEE
On January 24, 2017, the Canada Revenue Agency (CRA) released an update to its "Guidelines for determining the tax treatment of certain exploration expenses" that were previously issued in 2007.
Canada
1 Mar 2017
5
Investment Banking Fees For Advising On Takeover Bid Deductible
The Tax Court of Canada has decided that fees paid by a bidder to investment bankers for advice that assists the bidder in assessing whether or not a bid should be made are fully deductible.
Canada
26 Jul 2016
6
Mark-To-Market Recognition Of Foreign Exchange Gains/Losses For Tax Purposes
Kruger carried on a business of speculating on foreign exchange currency options. The options held by Kruger in 1998 could be closed by purchasing an offsetting option contract, rolled over to the next year or transferred.
Canada
6 Jul 2016
7
Solicitor-Client Privilege: Accounting Records Exception In Income Tax Act Unconstitutional
Two recent decisions by the Supreme Court of Canada considered demands for information made to lawyers and notaries issued by the Canada Revenue Agency (CRA).
Canada
1 Jul 2016
8
Tim Horton's RRRolls Up The Rim In Interest Deduction Win
The Federal Court of Appeal has allowed The TDL Group Co. (TDL) to deduct interest on borrowed money which was used to acquire common shares of a wholly-owned US subsidiary, reversing the Tax Court decision rendered last year.
Canada
15 Mar 2016
9
Cassels Brock Federal Budget Brief 2014
The following is a summary of certain fundamental tax measures contained in the Canadian federal government’s budget released on February 11, 2014.
Canada
12 Feb 2014
10
Crowdfunding Proceeds May Be Taxable
Crowdfunding has been defined as "the practice of funding a project or venture by raising many small amounts of money from a large number of people, typically via the Internet".
Canada
8 Oct 2013
11
Share Purchase Agreements And Cross-Border Tax: Tax Issues In The Purchase And Sale Of Shares
An M&A Series by Cassels Brock, partner Andrew Reback looks at tax related issues that may arise whenever shares of companies are purchased or disposed of.
Canada
17 May 2013
12
Share Purchase Agreements And Cross-Border Tax Issues (CBB Corporate Counsel Insights Video Series)
In this video from the CBB Corporate Counsel Insights Series, partner Andrew Reback discusses share purchase agreements and cross-border tax issues.
Canada
20 Feb 2013
13
Principal Differences In The Tax Treatment Of "Public Corporations", "Private Corporations" And "Canadian-Controlled Private Corporations"
Although a class of shares of a corporation may be publicly-listed, such a corporation may not necessarily qualify as a "public corporation" under the Tax Act.
Canada
7 Feb 2013
14
Canada Revenue Agency Tax Ruling — Conversion Of A Dutch BV Into A Dutch Cooperative
The Canada Revenue Agency released an advance tax ruling recently dealing with the consequences under the Income Tax Act (Canada).
Canada
26 Sep 2012
15
Foreign Spin-Offs
Canadian residents frequently own shares in foreign corporations (a "Distributor") that "spin off" shares of their foreign subsidiaries (a "Spin-out Corporation") to shareholders.
Canada
21 Sep 2012
16
The Ontario Foreign Tax Credit Regime After Harmonization
Tax advisers to Canadian corporations paying foreign taxes will routinely consider the federal foreign tax credit rules and the deduction under subsection 20(12) of the Income Tax Act (Canada) (the "ITA").
Canada
21 Sep 2012
17
Ontario Adopts New "Wealth Tax"
On June 20, 2012, Ontario’s legislature passed a bill that introduces a 2% tax increase on the taxable income of individuals in excess of $500,000.
Canada
2 Jul 2012
18
Changes To Canada’s Income Tax Act And Impact On Equipment Finance
On January 1, 2008, the Canadian government amended the Income Tax Act (Canada) to eliminate withholding taxes on interest payments for arm’s length loan transactions so long as the interest payments are not dependent or computed by reference to revenue, profit, cash flow, commodity price or any similar criteria (“Participating Debt”).
Canada
12 May 2009
19
An Overview Of Canadian Tax Credits For Non-Indigenous Film And Television Production
Canada, often referred to as “Hollywood North”, continues as a leading innovator in the development and implementation of public sector incentives for film and television production.
Canada
2 Mar 2009
20
“Lipson v. Canada” - A Sworded Tale!
In a split decision rendered in January 2009, the Supreme Court of Canada ("SCC") applied the general anti-avoidance rule under section 245 of the “Income Tax Act” (Canada) (the "Act") to deny interest deductibility in the highly anticipated “Lipson” decision.
Canada
26 Feb 2009
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