Two cases from the Federal Court of Appeal in Canada have opened the door for greater scrutiny of trust arrangements. This new case law, coupled with an emboldened Canada Revenue Agency, will probably mean more pressure on taxpayers that set up these vehicles to avoid income tax. Erin Kelechava looks at the way these cases will affect tax planning and how they may be illustrative of a broader trend against tax avoidance in Canada.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
Gregor McMillan of Howden explains how insurance-backed financing can help businesses and funds unlock liquidity from tax receivables and other contingent claims
The big four firm has been embroiled in a scandal over partners’ misuse of confidential board papers to pitch for and win corporate audits for Westpac and Dexus
Drawing on lessons from the PepsiCo case, tax lawyer Paul McNab explains why the ATO's latest royalty guidance should concern multinationals well beyond the technology sector
As pillar two exposes the limits of fragmented tax processes, organisations are rethinking their operating models to create the trusted data foundations that AI demands