Our new periodic newsletter, Tax Insights, will keep you up-to-date on a broad range of corporate and personal tax issues.
Tax Insights: Supreme Court of Canada rules in favour of taxpayers in Québec ‘rectification’ cases Rectification cases are of interest to the tax community because the truth is, mistakes happen. Sometimes the only solution is to attempt to rectify the legal steps. At common law, rectification is an equitable remedy that may be available through the superior courts of the common law provinces.
Tax Insights: Alert for financial services industry: Measures of interest in Bill C-4 (2013 budget bill) This Tax Insights looks at four anti-avoidance measures introduced in the 2013 federal budget of particular interest to the financial services industry. The proposed rules create fundamentally new tax concepts not previously seen in the Income Tax Act.
Tax Insights: Canada’s new non-resident trust rules: What they mean for global equity plans Newly enacted non-resident trust (NRT) rules will likely create tax liabilities and filing requirements for global equity plans that use foreign trusts and have Canadian-resident participant employees.
Tax Insights: Improved processing for Regulation 102 and 105 waiver applications A recent change announced by the CRA means that some non-residents who perform services in more than one location in Canada may send their Regulation 102 or Regulation 105 waiver applications to a Tax Services Office that has been designated as an International Waivers Centre of Expertise.
Tax Insights: SR&ED Form T661 revised: Claim preparer information required On October 31, 2013, the Canada Revenue Agency released revised Form T661, Scientific Research and Experimental Development Expenditures Claim, which contains new Part 9 – Claim preparer information. The revised form is required for claims filed starting January 1, 2014.
Tax Insights: Ontario increases personal taxes on some dividends and studies corporate tax incentives According to Ontario’s fall economic statement, presented today by Finance Minister Charles Sousa, the government will study an incentive that rewards research and development (R&D) incremental spending and “pay or play” tax incentives.
Tax Insights: New US Medical Device Excise Tax: What it means for your company Since January 1, 2013, manufacturers, producers and importers of medical devices have been liable for a 2.3% US federal excise tax, known as the Medical Device Excise Tax (MDET), on sales made in the US.
Tax Insights: QST: Simplified method eliminated – What this means for large businesses Starting January 1, 2014, large businesses can no longer use the simplified method (5%) to calculate input tax refunds (ITRs) in respect of expense reimbursements and allowances paid to employees.
Tax insights: Introduction of a refundable tax credit for the integration of Information Technologies in manufacturing SMEs (No. 2013-14) The objective of this new program from the Quebec Government is to support Quebec manufacturing companies that want to invest in technology and integrate IT in their business processes by offering a refundable tax credit pertaining to expenditures on qualified management software package.
Tax Insights: The Transalta case: Can stock plans be deductible in Canada? In Transalta Corporation v. The Queen, the Tax Court of Canada (TCC) found that shares issued under a performance share unit plan were a deductible corporate expense.
Tax Insights: Non-resident trust rules enacted: Transitional measures to consider Newly enacted rules for non-resident trusts include relief for NRTs that have property contributed by non-Canadian residents. If an NRT is eligible for this relief, an election must be made to obtain the benefit. Other transitional rules may also be available to an NRT.
Tax Insights: Taxable benefit rate rising to 2%: Act before October 1, 2013 The federal prescribed interest rate for taxable benefits will increase to 2% on October 1, 2013. The rate – which is subject to change every quarter – has been 1% since April 1, 2009. To lock in the 1% rate and save tax, you must act before October 1, 2013.
Tax Insights: Recent CRA practices deny Regulation 102 waiver requests Recent Canada Revenue Agency (CRA) practices have made it difficult for some non-resident employees working in Canada to obtain CRA waiver approval.
Tax Insights: Preventing treaty shopping: Finance seeks input on possible measures – Issue 2013-09 The Department of Finance has released a consultation paper on possible measures to prevent ‘treaty shopping.’ Comments must be submitted to Finance by December 13, 2013.
Tax Insights: More details needed on Foreign Income Verification Statement (Form T1135): Ensure you comply Taxpayers required to file Form T1135, 'Foreign Income Verification Statement,' must include additional information on foreign property, starting taxation years ending after June 30, 2013.
Tax Insights: Extension of and improvement to the TCEB until 2025 Extension of the refundable tax credit for the development of e-business (TCEB) to 2025, raising of the tax credit cap for eligible employees to the amount of $22,500, and clarifications regarding the activities that qualify for the purpose of issuing certificates for employees.
Tax Insights: Bill C-48 gets royal assent — Implications for Canadian companies with foreign affiliates This Tax Insights focuses on foreign affiliate measures in Bill C-48, Technical Tax Amendments Act, 2012, which received royal assent on June 26, 2013. It highlights some important dates.
Tax Insights: July 12, 2013 draft legislative proposals: Important implications for foreign affiliates Canadian corporations with foreign affiliates may be affected by draft legislative proposals released by the Department of Finance on July 12, 2013.
Tax Insights: British Columbia budget — June 2013 (Issue 2013-04) On Thursday, June 27, 2013, British Columbia’s Minister of Finance, the Honourable Michael de Jong, introduced the province’s post-election budget.
Tax Insights: Supreme Court of Canada ruling in Daishowa-Marubeni — Tax treatment of reforestation obligations on sale of forestry assets John Saunders of Wilson & Partners LLP was successful in arguing the Daishowa-Marubeni case in the Supreme Court of Canada.
Tax Insights: Does your documentation reflect the five questions? To support a scientific research and experimental (SR&ED) claim, contemporaneous documentation should reflect the current 5-question assessment approach – a refinement of the three-criterion approach.
Tax Insights: Changes to Quebec's mining tax regime After several months of deliberation and uncertainty, the Quebec government has finally announced changes to its mining tax regime.
Tax memo: US federal payroll tax requirements: Action must be taken by June 30, 2013 (Memo No. 2013-16) Outlines a US program that gives employers a way to reduce US federal payroll tax penalties if they act before June 30, 2013.
2013 Ontario Budget On May 2, 2013, Ontario’s Minister of Finance, Charles Sousa, presented the province’s 2013 budget. The budget does not change corporate or personal income tax rates.
Tax memo: 2013 Manitoba budget (Memo No. 2013-14) On Tuesday, April 16, 2013, Manitoba’s Minister of Finance, Stan Struthers, presented the province’s 2013 budget, raising provincial sales taxes from 7 to 8 per cent.
Tax memo: 2013 Federal budget – Alert for mining companies (Memo No. 2013-13) This Tax memo outlines unexpected proposals in the 2013 federal budget that affect Canada’s mining industry.
Tax memo: Changes to GST/HST rules for pension plans (Memo No. 2013-12) Pension plan tax compliance could be simplified by proposals in the 2013 federal budget.
2013 Federal Budget: Full commentary Read our analysis of the 2013 federal budget to learn about the tax implications for you. The budget does not change corporate tax rates.
Tax memo: OECD paper on aggressive tax planning based on after-tax hedging (Memo No. 2013-10) An OECD report describes aggressive tax planning that is based on after-tax hedging, as well as strategies of tax authorities and the challenges they face.
Tax memo: British Columbia PST regulations released (Memo No. 2013-09) This Tax memo highlights significant provisions of the PST Regulation and the Exemption and Refund Regulation.
Tax memo: Tax-free savings accounts (TFSAs): Making the most of them (Memo No. 2013-08) This Tax memo helps you maximize the benefits and navigate the complexities of TFSAs.
Tax memo: Will your foreign-based transfer pricing documentation withstand CRA scrutiny? (Memo No. 2013-07) How to ensure your Canadian transfer pricing documentation meets CRA standards.
Tax memo: 2013 British Columbia budget (Memo No. 2013-06) Finance Minister Mike de Jong tabled B.C.'s budget on February 19, 2013, increasing both corporate and personal taxes.
Tax memo: Immigration trusts: Tax planning for new Canadians (Memo No. 2013-05) This Tax memo explains how an immigrant to Canada can save tax on income generated by assets.
Tax memo: OECD report on “base erosion and profit shifting” looks to action plan (Memo No. 2013-04) An OECD report considers how base erosion and profit shifting could be addressed, and commits to developing an action plan within six months.
Tax memo: Withdrawal of General Preferential Tariff (GPT) treatment: Provide your input! (Memo No. 2013-03) Provide your input – you could pay more duty if GPT treatment is withdrawn from 72 countries.
Tax memo: 2013 Annual tax filing and remittance deadlines for corporations (Memo No. 2013-02) This Tax memo outlines some of the more common corporate compliance requirements to be considered at this time of year.
Tax memo: RESPs: A user’s guide (Memo No. 2013-01) This Tax memo helps you navigate the complexities and maximize the benefits of RESPs.