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.
This article identifies challenges in interpreting regulations 5907(1.5) and (1.6) and explores the potential significance of their enactment relative to other provisions of the Income Tax Act and regulations that compute amounts based on foreign tax payments.
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.
The 2014 year continued to bring significant changes to the global transfer pricing landscape, which in turn influenced the Canadian transfer pricing environment.
This article discusses the treaty shopping proposals in the September 2014 Organisation for Economic Co-operation and Development (OECD) report and Canada’s 2014 federal budget, commenting on the direction that Canada may take to counter treaty shopping.
This article provides an overview of the "final" FA reorganization rules and includes a discussion of the practical planning considerations that arise when working with these provisions.
Do large Canadian corporations pay their fair share of taxes? This short article highlights the issues and the findings of a survey of 63 top Canadian companies.
Adding strategic value to the organization is now part of the global tax leader’s role. The challenge is to overcome inefficient manual processes through well-chosen strategic investments in people, processes, technology and data.
BEPS is likely to have important implications on indirect tax in the digital economy. The OECD is studying the topic, and Canada’s Department of Finance has sought input from stakeholders.
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