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Publication cover for Tax Insights: Voluntary Disclosures Program – Drastic changes underway”'

Tax Insights: Voluntary Disclosures Program – Drastic changes underway

Draft Information Circular – IC00-1R6 – Voluntary Disclosures Program (VDP), which was recently released by the Canada Revenue Agency for discussion purposes, proposes numerous changes that would significantly alter the VDP.


Publication cover for Tax Insights: GST/HST payable by investment plans on deferred sales commissions funding arrangements – TCC’s decision in Invesco”'

Tax Insights: GST/HST payable by investment plans on deferred sales commissions funding arrangements – TCC’s decision in Invesco

The Tax Court of Canada (TCC) in SLFI Group - Invesco Canada Ltd. considered the application of the financial service exemption for GST/HST purposes.


Publication cover for Tax Insights: Government progress report vows to crack down on “tax cheats”'

Tax Insights: Government progress report vows to crack down on “tax cheats”

On June 1, 2017, the Minister of National Revenue (Minister) outlined how the government is addressing six of the 14 recommendations in the House of Commons Standing Committee on Finance report “The Canada Revenue Agency, Tax Avoidance and Tax Evasion: Recommended Actions.”


Publication cover for Tax Insights: Federal Court of Appeal limits CRA access to tax accrual working papers'

Tax Insights: Federal Court of Appeal limits CRA access to tax accrual working papers

On March 30, 2017, the Federal Court of Appeal ruled that the Minister of National Revenue does not have “general and unrestricted access” to taxpayers’ identification of their uncertain tax positions.


Publication cover for Tax Insights: Government commits to aggressive timelines for recommendations on tax avoidance and tax evasion'

Tax Insights: Government commits to aggressive timelines for recommendations on tax avoidance and tax evasion

On February 22, 2017, the Minister of National Revenue responded to the 14 recommendations in the House of Commons Standing Committee on Finance report “The Canada Revenue Agency, Tax Avoidance and Tax Evasion: Recommended Actions,” dated October 26, 2016.


Publication cover for Insights: New real property register requirement for OBCA corporations – Ensure you comply'

Insights: New real property register requirement for OBCA corporations – Ensure you comply

A recent amendment to the Ontario Business Corporations Act requires Ontario corporations to create and maintain a register of their ownership interests in land in Ontario. Corporations incorporated on or after December 10, 2016, must comply immediately. Other Ontario corporations have a two-year transition period.


Publication cover for Tax Insights: Voluntary Disclosures Program in jeopardy'

Tax Insights: Voluntary Disclosures Program in jeopardy

On December 8, 2016, the Canada Revenue Agency released “Report on the Voluntary Disclosures Program” (VDP), which sets out recommendations of the Offshore Compliance Advisory Committee. The report states that the 11 recommendations are designed to “enhance and improve” the VDP.


Publication cover for 'Tax Insights: OECD releases long-awaited multilateral instrument – What it means for BEPS'

Tax Insights: OECD releases long-awaited multilateral instrument – What it means for BEPS

On November 24, 2016, the Organisation for Economic Co-operation and Development (OECD) released the long-awaited Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, also described as the “multilateral instrument.”


Publication cover for 'Tax Insights: CRA fishing net expands'

Tax Insights: CRA fishing net expands

The Canada Revenue Agency intends to expand its review of international electronic funds transfers (EFTs); in 2017-18 it will review 100,000 EFTs involving targeted jurisdictions. As a result of this strategic audit initiative, many taxpayers can expect an “EFT letter” next year as part of their increasing compliance burden.


Publication cover for 'Tax Insights: GST/HST alert – Participating employers must remit GST/HST collected on deemed supplies to pension entities – act by December 31, 2016 '

Tax Insights: Participating employers must remit GST/HST collected on deemed supplies to pension entities – act by December 31, 2016

Proposed GST/HST legislation released by the Department of Finance on July 22, 2016, has important implications for pension entities including those that use a master pension entity (i.e. master trust).


Publication cover for 'Tax Insights: House of Commons Standing Committee on Finance targets tax avoidance and evasion'

Tax Insights: House of Commons Standing Committee on Finance targets tax avoidance and evasion

On October 27, 2016, the House of Commons Standing Committee on Finance released its report “The Canada Revenue Agency, Tax Avoidance and Tax Evasion: Recommended Actions.” The report summarizes the testimony received by the Committee during three hearings and includes 14 recommendations.


Publication cover for 'Tax Insights: GST/HST alert for pension plans and master trusts'

Tax Insights: GST/HST alert for pension plans and master trusts

On July 22, 2016, the Department of Finance released draft GST/HST legislative amendments that affect pension plans, including those that use master trusts or master corporations. Although the new rules generally apply to fiscal years starting after July 22, 2016, some are retroactive to September 23, 2009. So, you should assess their implications now.


Publication cover for 'Tax Insights: SCC strikes down Minister’s authority to demand records subject to privilege?'

Tax Insights: SCC strikes down Minister’s authority to demand records subject to privilege

Two recent Supreme Court of Canada cases are the latest of recent developments reminding taxpayers that communications involving tax risks and strategy can be subject to privilege, and therefore do not have to be disclosed to the Canada Revenue Agency.


Publication cover for 'Tax Insights: July 1, 2016 – Ontario recapture rate for recaptured input tax credits declines

Tax Insights: July 1, 2016 – Ontario recapture rate for recaptured input tax credits declines

On July 1, 2016, Ontario’s rate for certain businesses to recapture the provincial portion of Ontario HST claimed as ITCs in respect of specified property and services will decline from 75% to 50%. The rate is being phased out over four years.


Publication cover for 'In Print: The

In Print: The "Purpose" of Subsection 55(2)

Subsection 55(2) of the Income Tax Act is a specific anti-avoidance rule aimed at "capital gain strips" and has been in the Act for over 30 years.


2016 Federal budget: A new era with a majority Liberal government

2016 Federal budget: A new era with a majority Liberal government

On March 22, 2016, the Federal Minister of Finance, Bill Morneau, presented the new majority government’s first budget. This Tax Insights discusses the tax initiatives proposed in the budget.


Publication cover for 'Newfoundland and Labrador increases HST rate to 15% and reintroduces 15% RST on property and casualty insurance premiums '

Tax Insights: Newfoundland and Labrador increases HST rate to 15% and reintroduces 15% RST on property and casualty insurance premiums

Newfoundland and Labrador’s 2016 budget increases the province’s HST rate to 15% on July 1, 2016, with the provincial portion of the HST increasing from 8% to 10%.


Tax Insights: New initiatives target tax evasion and tax avoidance

On April 11, 2016, the Honourable Diane Lebouthillier, Minister of National Revenue, outlined measures that the government will implement to combat what it perceives as “aggressive” tax avoidance – strategies that adhere to Canada’s tax laws but may contravene its intention – and tax evasion.


Tax Insights: 2016 Federal budget – GST/HST relieving measures for non-arm’s length cross-border reinsurance

Tax Insights: 2016 Federal budget – GST/HST relieving measures for non-arm’s length cross-border reinsurance

The March 22, 2016 federal budget announced measures concerning the application of GST/HST on reinsurance premiums that are paid to non-arm’s length non-resident insurers. These measures will apply to any year ending after November 16, 2005.


Tax Insights: Partnership exemption for Ontario land transfer tax retroactively eliminated for trusts and partnerships

Tax Insights: Partnership exemption for Ontario land transfer tax retroactively eliminated for trusts and partnerships

On February 18, 2016, the Ontario Ministry of Finance introduced certain retroactive amendments to Regulation 70/91 under the Land Transfer Tax Act (the Amendments). The Amendments disqualify trusts and partnerships from using the land transfer tax exemption that is available for transfers of a beneficial interest in land by way of certain transfers of partnership interests.


Tax Insights: Newfoundland and Labrador’s HST rate to remain 13%

Tax Insights: Newfoundland and Labrador’s HST rate to remain 13%

Newfoundland and Labrador’s Premier-designate, Dwight Ball, has confirmed that the province’s HST rate will remain 13%. The former government had planned to increase the rate to 15% on January 1, 2016 (i.e. the provincial portion of the rate was to increase from 8% to 10%).


In Print: George Weston and the Characterization of Gains on Derivatives

In Print: George Weston and the Characterization of Gains on Derivatives

The authors of this article argue that the Tax Court of Canada’s decision in George Weston Limited v. The Queen is a natural and expected result of 75 years of UK and Canadian jurisprudence on the treatment of foreign exchange gains and losses and gains and losses arising from hedging activity such as currency swaps and commodity futures trading.


Tax Insights: New QST filing and reporting requirement for investment plan managers – Action required by November 20, 2015

Tax Insights: New QST filing and reporting requirement for investment plan managers – Action required by November 20, 2015

Significant QST legislative amendments concerning investment plan managers received royal assent on October 21, 2015.


Publication cover for 'Tax Insights: July 1, 2015'

Tax Insights: GST/HST and QST alert – Investment plans are required to obtain investor percentages – actions required by September 30, 2015

Distributed investment plans that are a selected listed financial institution are required to obtain information from investors to determine the plan provincial attribution percentage, so that the plan's GST/HST and QST liabilities can be calculated. Exchange-traded funds and exchange-traded series are excluded from this requirement.


Publication cover for 'Tax Insights: July 1, 2015'

Tax Insights: July 1, 2015 – Ontario phases out recapture rate for recaptured input tax credits

This Tax Insights summarizes the changes to the recaptured input tax credit (RITC) reporting requirements.


Publication cover for 'In Print: Recommended Amendments to the Upstream Loan Rules'

In Print: Recommended Amendments to the Upstream Loan Rules

The upstream loan rules announced on August 19, 2011 and enacted on June 26, 2013 require an analysis of all loans or indebtedness owing to foreign affiliates of a Canadian taxpayer.


Publication cover for 'Top 10 considerations if you're being audited by the CRA'

Top 10 considerations if you're being audited by the CRA

Whether this is the first time you have been selected for an audit, or you have undergone previous audits by the Canada Revenue Agency (CRA), there are a number of key actions by the taxpayer that can minimize the effort and time invested, reduce the potential for reassessment and allow you to exercise some control over the conduct of the audit.


Publication cover for 'All’s Well That Ends Well… the happy result of long delay'

All’s Well That Ends Well… the happy result of long delay

The Canada Revenue Agency (the “CRA”) has for many years been concerned with taxpayers who transfer commuted pension plan benefits to individual pension plans where such transfers result in significant surplus assets in the new plan and, in the CRA’s view, insignificant amounts of salary earned by the taxpayer.


Publication cover for 'The Inward Investment and International Taxation Review'

The Inward Investment and International Taxation Review

The Inward Investment and International Taxation Review provides topical and current insights from leading experts on the tax issues and opportunities in their respective jurisdictions.