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November 22, 2011
Canada is one step closer to enhanced tax cooperation and will soon be involved in simultaneous and international tax examinations, argues Carrie Aiken Bereti of Blake, Cassels & Graydon.
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October 01, 2011
On August 19 2011, the Canadian Department of Finance released a package of proposed amendments including significant changes to the tax rules governing the taxation of income earned by foreign affiliates of Canadian taxpayers (the proposals).
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September 01, 2011
Court says Canadian tax will not be affected by how a transaction is characterised for foreign tax purposes.
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August 09, 2011
Kathleen Penny explains how to avoid friction with the CRA over outbound loans arrangements
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July 05, 2011
Companies now have better insight into the application of administrative penalties.
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June 08, 2011
The Bozzer decision offers new hope for reducing arrears and deficiency interest and penalties in transfer pricing and tax avoidance disputes.
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February 14, 2011
Jean Marc Gagnon and Emmanuel Sala from Blake, Cassels & Graydon analyse a case discussing residency and incorporation requirements under the Canada-UK Tax Convention.
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December 21, 2011
Despite mounting international pressure, the Court of Justice of the European Union (CJEU) has today confirmed that aviation can be brought under the emissions trading scheme (ETS) without breaking international law.
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December 19, 2011
Canadian taxpayers should expect more uncertainty when it comes to the country’s general anti-avoidance rule (GAAR) despite last week’s Copthorne ruling, warns a leading lawyer.
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December 16, 2011
Canada’s Supreme Court dismissed the appeal of Copthorne Holdings Ltd today, finding that a return of capital payment to a shareholder was an abusive tax transaction.
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December 16, 2011
The Canadian tax authorities are ready to step up their scrutiny of taxpayers’ risk management.
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November 22, 2011
Canada is one step closer to enhanced tax cooperation and will soon be involved in simultaneous and international tax examinations, argues Carrie Aiken Bereti of Blake, Cassels & Graydon.
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November 22, 2011
After the publication of new proposed rules on corporate tax deferral, the Canada Revenue Agency has now issued guidance dealing with interim filing for the proposals.
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November 09, 2011
The Canadian Department of Finance has released for public comment a package of draft legislative proposals relating to a number of technical changes to the country’s tax laws.
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November 08, 2011
David Gillon, representative of HMRC in the UK and the Joint International Tax Shelter Information Centre (JITSIC), told delegates at the IBA annual conference of the benefits that JITSIC is providing.
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November 02, 2011
Taxpayers will have to put up with an increased compliance burden as global efforts to improve information exchange grow, but the benefits are just around the corner, say international specialists.
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October 06, 2011
A ruling from Canada’s Federal Court of Appeal will have implications for taxpayers that sell a business where pension, severance or other obligations are assumed by the purchaser.
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October 04, 2011
Ed Kroft QC of Blake, Cassels & Graydon in Canada describes the differences between joint and simultaneous audits, their benefits and disadvantages and speculates that it is only a matter of time before they will form part of the Canadian and OECD member tax landscape.
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September 01, 2011
The Canadian Ministry of Finance has released a set of draft amendments for the rules affecting foreign affiliates. A significant portion of the proposed legislation concerns foreign mergers.
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September 01, 2011
Court says Canadian tax will not be affected by how a transaction is characterised for foreign tax purposes.
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August 24, 2011
Canadian Finance Minister Jim Flaherty on August 19 announced income tax proposals for foreign affiliate companies which include changes to stop-loss rules and surplus regulations.
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August 19, 2011
The intra-America tax information exchange agreement (TIEA) was signed on August 11 in San José.
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August 09, 2011
Kathleen Penny explains how to avoid friction with the CRA over outbound loans arrangements
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August 01, 2011
Canadian Finance Minister Jim Flaherty announced possible plans to close a corporate tax loophole associated with specified investment flow-through (SIFT) entities.
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July 05, 2011
Companies now have better insight into the application of administrative penalties.
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June 23, 2011
Canada and Bermuda will sign a tax information exchange agreement (TIEA) to go into effect July 1.
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June 20, 2011
A recent decision from Canada’s Federal Court of Appeal offers taxpayers new hope for getting relief from interest and penalties payments in transfer pricing and tax avoidance disputes.
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June 09, 2011
Canada’s Conservative Party is set to take advantage of the majority it won in a general election last month to cut the corporate tax rate from 16.5% to 15%.
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April 26, 2011
Canada goes to the polls on May 2 when the crucial issue of carbon taxes is expected to loom large in the minds of voters. Opposition parties are in general agreement that cap-and-trade is the best method to use. However, in Australia a lack of consensus on carbon taxes might bring down the government.
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March 30, 2011
The Supreme Court of Canada granted the Crown’s leave to appeal in the case of The Queen v GlaxoSmithKline Inc on March 24.
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March 23, 2011
Canada’s 2011 budget, which was published on March 22, had a short life.
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March 10, 2011
US multinationals are not unfamiliar with fighting over the tax treatment of stock option expenses. Tax practitioners believe that the next round in this battle may focus on the tax treatment of stock options across the Canadian border.
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March 01, 2011
Countries around the world are improving their auditing efforts to compensate for overwhelming debt burdens and Canada is no exception.
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February 04, 2011
The Supreme Court of Canada heard arguments in the case of Copthorne Holdings Ltd v The Queen on January 21.
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January 14, 2011
Ed Kroft, QC, of Blake Cassels & Graydon discusses recent concerns of the Canadian courts about the increase in the number of procedural disputes in Canadian transfer pricing and tax avoidance cases.
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January 03, 2011
The Federal Court of Canada (FCA) has confirmed a lower court decision holding that the payment of a taxpayer’s guarantee fee was in keeping with the arm’s length standard.
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September 12, 2011
Tax Controversy Leaders is a guide to the leading tax dispute resolution lawyers and advisers in the world. In addition to highlighting tax professionals, the guide also includes litigators and barristers who may not practise tax on a day to day basis.