Our Tax memo Publications
View this page in: FrançaisTax memo: CRA risk assessment audit approach – What it can mean for your corporation The Canada Revenue Agency (CRA) has now advanced to the next stage of categorizing large corporations in implementing its new risk assessment approach of selecting files for audit.
Tax memo: Alert for RRSP and RRIF holders: Action is required if a new “prohibited investment” rule applies to you (Revised February 3, 2012) Newly enacted legislation that implements proposals announced in the 2011 federal budget imposes new penalty taxes for some prohibited investments
Tax memo: 2012 Annual tax filing and remittance deadlines for corporations (Memo No.: 2012-02) Canadian corporations may be required to meet several Canadian annual filing and remittance deadlines. Learn more about common compliance requirements.
Tax memo: Pooled Registered Pension Plans — Tax rules introduced (Memo No.: 2012-01) This tax memo outlines the rules for Pooled Registered Pension Plans (PRPPs)–voluntary savings plans aimed at individuals who do not have access to employer-sponsored pension plans.
Tax memo: Reflections on Supreme Court ruling on GAAR—Copthorne Holdings Ltd. Read this Tax memo for a commentary on the Supreme Court’s decision on the general anti-avoidance rule (GAAR) decision handed down in the Copthorne Holdings Ltd. v. The Queen case.
Tax memo: Payments to non-residents: How new CRA guidelines and forms affect investment vehicles and other investors New CRA guidelines specify the information Canadian payers must obtain to support withholding tax at a treaty-reduced rate on dividends, interest, management fees, rents and royalties paid to or for the benefit of non-residents.
Tax memo: Supreme Court of Canada GAAR ruling on Copthorne Holdings Supreme Court of Canada (SCC) makes a decision on the Copthorne Holdings general anti-avoidance rule (GAAR) case.
Tax memo: Pooled Registered Pension Plans: A new retirement savings vehicle The federal government has introduced legislation designed to reduce the cost of pension plans for small employers.
Tax memo: QST rate increasing on January 1, 2012 On January 1, 2012, the QST rate will be increasing. Learn more about special transitional rules and how to prepare.
Tax memo: Payments to non-residents: How new CRA guidelines and forms affect financial institutions New Canada Revenue Agency (CRA) administrative guidelines affect financial institutions and other agents that administer payments made on Canadian securities. Learn more about the information Canadian institutions need to obtain.
Tax memo: QST to be harmonized with GST by 2013 Learn about the implications of the September 30, 2011 announcement by the Quebec government to harmonize the QST with the GST.
Tax memo: Prohibited investment rules extended: Alert for RRSPs and RRIFs with investment fund holdings RRSP and RRIF annuitants can now be subject to penalty taxes if these plans hold a share of, interest in or a debt of an investment fund.
Tax memo: New Tax Court of Canada rulings on GAAR—1207192 Ontario Limited and Triad Gestco On September 7, 2011, the Tax Court of Canada (TCC) released its decision in 1207192 Ontario Limited v. The Queen, 2011 TCC 383.
Tax memo: B.C. votes to extinguish HST BC votes to eliminate the HST and reinstate the PST. Learn what this means for your business.
Tax memo: Long-awaited foreign affiliate amendments released The new foreign affiliate amendments have revised previously released proposals and include some surprise. Learn more in this Tax memo.
Tax memo: Consultation draft released On August 16, 2011, the Department of Finance released draft legislative proposals to implement tax measures from the 2011 federal budget. This publication highlights certain clarifications to the budget proposals made by the draft legislation.
Tax memo: Proposed Changes for SIFTs, REITs and publicly traded corporations The Department of Finance proposes to constrain publicly traded stapled securities structures. The changes include new rules that will apply in respect of stapled securities. Learn more in this Tax memo.
Tax memo: Possible relief for pension plans filing GST 494 SLFI returns – Action required by June 30, 2011 Officials at the federal Department of Finance have indicated informally that relieving measures for pension plans will be incorporated into the SAM calculation on the GST 494 return, due on June 30, 2011.
Tax memo: Canada TIEAs: Status at June 8, 2011 Get the latest update to the status of Tax Information Exchange Agreements (TIEAs) in this PwC publication.
Tax memo: Withholding tax on royalty payments to a sister company A recent CRA audit position raises potential withholding tax issues for some companies that pay royalties to related companies in the United States. Get the facts in this Tax memo.
Tax memo: Permanent establishments in Canada: New CRA views raise concerns On May 4, 2011, the CRA issued a technical interpretation on whether two US companies would have a permanent establishment in Canada for purposes of Article V(9)(b) of the Canada-US Tax Treaty. Read this Tax memo for PwC’s observations.
Tax memo: 2011 Federal Budget Ends Deferral Corporate Income Tax Partnerships Corporate partners with taxation years ending after March 22, 2011, could be affected by budget measures that curtail the deferral of partnership income.
Tax memo: Payments to non-residents: CRA issues new treaty-based withholding forms New CRA forms signal increased documentation demands on taxpayers that make payments to non-residents and on the non-resident recipients.
Tax memo: Federal Budget Includes RRSP Anti-Avoidance Rule The federal budget extends to RRSPs anti-avoidance rules that already apply to Tax-Free Savings Accounts. As a result, RRSP investments in certain private business trusts could be subject to these rules, triggering severe penalties.
Tax memo: 2011 Manitoba Budget: Tax Highlights On April 12, 2011, Manitoba´s Minister of Finance, Rossan Wowchuk, presented the province´s 2011 budget.
Tax memo: 2011 Ontario Budget Download this Tax memo to read our analysis of the 2011 Ontario budget.
Tax memo: Finance Proposes Legislative Measures to Counter FCA Decisions On March 16, 2011, the Department of Finance released draft legislative proposals that would counter what it considered to be taxpayer-friendly decisions in three Federal Court of Appeal cases.
Tax memo: 2011 Federal Budget Federal Minister of Finance Jim Flaherty presented the minority government’s budget on March 22, 2011. Get our analysis in this Tax memo.
Tax memo: 2011 Quebec Budget Quebec's Minister of Finance Raymond Bachand presented the province's budget. Download this Tax memo for our response.
Tax Memo: IFRS and Tax: The Rubber has Hit the Road The move to IFRS from Canadian GAAP will fundamentally change the way Canadian companies report their business results. This Tax Memo considers these possibilities under three headings: financial statement effects, accounting for income taxes and computation of taxes payable.
Tax Memo: 2011 Annual Tax Filing and Remittance Deadlines for Corporations Use this Tax Memo as a reference guide for your 2011 tax filing and remittance deadlines, and compliance requirements.
Tax Memo: Deduction Denied for Amounts Paid to Employees for Stock Options in course of Going-Private Transaction (Imperial Tobacco case) In Imperial Tobacco Canada Limited v. The Queen, the Tax Court of Canada held that payments made by Imperial Tobacco to its staff to eliminate an employee stock option plan in the context of a going-private transaction were capital in nature and not deductible.
Tax Memo: Guarantee Fees: Federal Court of Appeal Confirms GE Capital Canada Inc. Decision On December 15, 2010, the FCA dismissed the Crown’s appeal of a 2009 TCC decision that favoured the taxpayer. Get the facts in this Tax Memo.
Tax Memo: Proposed Changes to Real Estate Investment Trust (REIT) Tax Rules Read this Tax Memo for PwC’s response to the Department of Finance’s December 16th REITs’ announcement.
Tax Controversy and Dispute Resolution: Tax Memo - Memorandum of Understanding (MOU) on the Canada-US Tax Treaty Arbitration Process Canadian and US competent authorities released an important MOU on the conduct of mandatory binding arbitration proceedings under the Canada-US Tax Treaty’s mutual agreement process. Learn more in this publication.
Tax Controversy and Dispute Resolution: Tax Memo – The FCA Decision in Antle The FCA’s decision in Antle v. The Queen may motivate the CRA to raise sham arguments more frequently. In this publication, learn the background, the CRA’s position and PwC’s observations.
Canadian National Tax Services: Tax Memo - Taxation of Corporate Groups – Consultation Paper Released This Tax Memo outlines the key points in the consultation paper, The Taxation of Corporate Groups.
Tax Memo: British Columbia Harmonized Sales Tax — Recapture of Input Tax Credits (Updated November 9, 2010) Some corporations may be required to record significant adjustments to future tax balances and income tax expense, to reflect corporate tax rate reductions implemented by Bill C-28, which received royal assent on December 14, 2007.
Tax Memo: Ontario Harmonized Sales Tax — Recapture of Input Tax Credits (Updated November 10, 2010) Read this PwC Tax Memo for the updates to three Ontario HST documents on recapturing input tax credits.
Tax Controversy and Dispute Resolution: Tax Memo – Late-Filed T1135: Court Denies Waiver of Penalties and Interest in Asper Holdings A recent Federal Court case demonstrates the need to ensure appropriate information returns are filed on time. Learn more about this case and its impact in this Tax Memo.
Tax Controversy and Dispute Resolution: Tax Memo – CRA Reassessments After the Normal Reassessment Period Recent reassessment cases raises concerns that the CRA could be broadening its assessing practices via an increased focus on aggressive tax planning. Read this special Tax Memo to learn more.
Tax Controversy and Dispute Resolution: Tax Memo -- Auditor General Gives the CRA’s Commitment to Service a Positive Review Get details on the CRA’s new process for handling service-related complaints from taxpayers in this special Tax Memo issue.
Tax Memo: HST Place of Supply Rules Overhauled (Updated October 20, 2010) This Tax Memo provides a review of the main place of supply rules under the HST regime and as outlined in the CRA’s Bulletin B-103.
Tax Controversy and Dispute Resolution: Tax Memo: “Risk Assessment” – The CRA’s New Audit Approach Will the CRA’s new process for selecting audit files impact your business, trust or partnership? Read this Tax Memo to learn the tax authority’s new risk model.
Tax Memo – Major GST/HST Changes for Pension Plans Two rules will change the way pension plans and employee sponsors are treated for GST/HST purposes. Learn more about them and how PwC can help evaluate their impact.
Tax Memo: New GST/HST Electronic Filing Requirement HST implementation in July 1, 2010, now means some registrants must file their GST/HST returns electronically. Read this Tax Memo to understand how the change affects your business.
Tax Memo: Partnership Information Returns – Who Must File Starting 2011? The CRA now requires partnerships to file based on financial thresholds and partner structure. Get PwC’s response to the announcement and other reporting requirements.
Tax Memo – New Federal Reporting Regime for Aggressive Tax Planning: Draft Legislation Released Learn about the Department of Finance’s release of a consultation draft on various legislative proposals including an information-reporting regime for certain tax avoidance transactions.
Tax Memo: August 27, 2010 Draft Legislation Implements 2010 Budget Proposals and Other Previously Announced Measures This Tax Memo examines measures included in the August 27, 2010 draft legislation that affect SIFTs, employee stock options, non-resident trust and offshore investment funds and more.
Tax Memo: Sales Tax Harmonization in British Columbia and Ontario – Manufacturing Under the HST, manufacturers pay more tax overall on their purchases but, they can recover most of it by claiming ITCs on their GST/HST returns. Learn more in this publication.
Tax Memo: Sales Tax Harmonization in British Columbia and Ontario – A Guide for Non-Residents HST implementation is the most substantial tax reform in British Columbia and Ontario in several years. This Tax Memo highlights key potential implications.
Tax memo: HST Transitional Rules for Ontario and British Columbia Released (Updated August 5, 2010) This Tax memo covers the phasing out of the PST and how to manage the transition to the HST.
Tax Memo: Sales Tax Harmonization – Financial Services (Updated August 4, 2010) Harmonization substantially increases the tax burden for the financial sector. Read this Tax Memo to learn how to address the move to the HST.
Tax Memo: Taxpayer Wins Appeal in Transfer Pricing Case (GlaxoSmithKline) – “Business Reality” Prevails The Federal Court of Appeal set aside the Tax Court’s May 2008 decision regarding the pricing of the active ingredient, ranitidine, in GlaxoSmithKline’s ulcer drug, Zantac. PwC shares the details in this Tax Memo.
Tax Memo: The CRA Accepts Refund Claims by U.S. LLCs Read this Tax Memo for information on the CRA’s acceptance of refund claims by US LLCs and PwC’s response to the decision.
Tax Memo: Canada Signs Four New Tax Information Exchange Agreements Canada signed Tax Information Exchange Agreements with four jurisdictions, a move that grants the areas access to Canada’s exempt surplus regime. Read this Tax Memo for more information.
Tax Memo: Foreign Exchange Hedges: The CRA’s Views on Gains and Losses Taxpayers who wish to change from capital to income treatment on foreign hedging transactions may be impacted by recent CRA opinion letters. Get the facts in this Tax Memo.
Tax Memo: The Move to IFRS: CRA Guidance This Tax Memo outlines the CRA’s recent comments on International Financial Reporting Standards (IFRS) and provides results of a PwC-sponsored survey on the IFRS readiness of Canadian companies.
Tax Memo: CRA Access to Documents This Tax Memo provides an overview of the CRA’s revised policy on access to taxpayer and third-party documents and its implications.
Tax Memo: Quebec’s Regime for Aggressive Tax Planning: Prescribed Form Released Revenue Quebec has recently released Form TP-1079.DI, "Mandatory or Preventative Disclosure of a Tax Plan."
Tax Memo: Federal Proposals for Reporting Tax Avoidance Transactions This Tax Memo discusses proposals released by the Department of Finance regarding the information-reporting regime for certain tax-avoidance transactions.
Tax Memo: The CRA Sanctions Intra-Group Lending Transactions Get an update from a CRA advance income tax ruling on proposed transactions for redeploying funds from a Canadian subsidiary of a foreign multinational corporation elsewhere in the corporate group.
Tax Memo: TD Securities: Tax Court of Canada Decision is Welcome News for LLCs The outcome in TD Securities (USA) LLC v. Her Majesty The Queen has significant implications for US LLCs with Canadian-source income.
Tax Memo: 2010 Quebec Budget Quebec's Minister of Finance Raymond Bachand presented the province's budget. Download this Tax Memo for our response.
Tax Memo: 2010 Ontario Budget On Thursday, March 25, 2010, Ontario's Minister of Finance, Dwight Duncan, presented the province's 2010 budget. Get PwC Canada's analysis and contact us for help determining the budget’s impact.
Tax Memo: 2010 Manitoba Budget: Tax Highlights Manitoba’s Minister of Finance Rosann Wowchuk presented the province’s budget. Read this Tax Memo for PwC's analysis.
Tax Memo: HST Place of Supply Rules Overhauled This Tax Memo provides a brief overview of the main place of supply rules under the new regime and as outlined in Bulletin B-103.
Tax Memo: Stock Options: 2010 Federal Budget Implications for Employers The federal government’s 2010 budget proposes significant changes to Canada’s stock options rules. Get help clarifying important aspects of the amendments from this Tax Memo.
Tax Memo: Mandatory E-filing of Corporate Income Tax and Information Returns Starting in 2010, the CRA requires certain corporate tax and information returns to be filed on the Internet. Read this Tax Memo for the requirements and non-compliance penalties.
Tax memo: 2010 British Columbia Budget Get PwC Canada's response to the BC budget in this Tax memo and contact us for help determining the budget’s impact on your business.
Tax Memo: 2010 Federal Budget The government froze EI and plans new rules for SIFT, group taxation and capital cost allowances in this year's federal budget. Get our response to these initiatives and more.
Tax Memo: British Columbia Harmonized Sales Tax —Recapture of Input Tax Credits BC’s Ministry of Finance released details on a temporary restriction of ITCs on the HST’s provincial portion for big businesses, including financial institutions. Get PwC’s analysis in this Tax Memo.
Tax Memo: 2010 Annual Tax Filing and Remittance Deadlines for Corporations Keep this PwC Tax Memo as a reference guide for your 2010 tax filing and remittance deadlines, and compliance requirements.
Tax Memo: Ontario Harmonized Sales Tax — Recapture of Input Tax Credits On February 1, 2010, Ontario’s Ministry of Revenue released three documents proposing large businesses repay input tax credits attributed to the HST’s provincial component. Learn more in this Tax Memo.
Tax Memo: Foreign Affiliates: Draft Regulations Released The Minister of Finance released a package of legislative proposals on the taxation of Canadian multinational corporations with foreign affiliates. Get a summary of the package in this Tax Memo.
Tax Memo: GST/HST: Retroactive Legislation Proposed to Tax Discretionary Investment Management Services The Department of Finance plans to announce legislation to clarify that discretionary investment management services are subject to the GST. Get PwC’s perspective in this Tax Memo.
Tax Memo: Guarantee Fees: Tax Court of Canada Rules in Favour of GE Capital Canada Inc. A long-awaited decision between GE Capital Canada Inc. vs. The Queen results in implications for pricing guarantee fees in Canada. PwC shares its observations in this Tax Memo.
Tax Memo: Taxable Employment Benefits – The CRA’s Revised Policy The CRA announced revisions to its administrative policies on taxable employment benefits that will have implications for employers and their staff. Read this Tax Memo to learn the ramifications.
Tax Memo: Bill 53: Good News for Alberta Professional Corporations This Tax Memo provides details on amendments to Alberta’s Bill 53 that remove restrictions on share ownership in a professional corporation.
Tax Memo: Ontario Sales Tax Harmonization – Input Tax Credit Restrictions This November 2009 publication, released by Ontario’s government, details special restrictions on ITCs for the provincial portion of the HST paid by large businesses.
Tax Memo: Revised Quebec Aggressive Tax Planning Proposals As of October 15, 2009, new measures released by the ministère des Finances will affect entities that are taxable in Quebec. This Tax Memo summarizes the disclosure requirements.
Tax Memo - Professional Corporations – An Attractive Option This PwC Tax Memo summarizes key issues professionals face when considering incorporation.
Tax Memo: HST Transitional Rules for Ontario and British Columbia Released Read our Tax Memo to learn how the transitional rules will affect the application of the HST on the sale of goods, services and other areas in Ontario and BC.
Tax Memo - 1% Taxable Benefit Rate: Action Required Before January 1, 2010 The federal interest rate for taxable benefits is 1% until December 31, 2009. Read this PwC Canada Tax Memo to learn different ways to lock in this rate.
Tax Memo - Customs Update: Unilateral Duty Reductions and Audit Targets The Canadian government has announced its intention to unilaterally remove the customs duty on a wide range of imported products.
Tax Memo: GST Rebate for Registered Pension Plan Trusts The Department of Finance’s new GST rebate for pension entities includes changes significantly different from 2007 proposal. Read this PwC Tax Memo to learn more.
Tax Memo: GST and the Financial Services Sector – Updated Draft Legislation Released Jim Flaherty released updated draft legislation on proposed changes to application of the GST to financial institutions. PwC discusses the draft’s features and differences from previous proposals.
Canada Signs its First Tax Information Exchange Agreement (TIEA) In August 2009, Canada signed a Tax Information Exchange Agreement (TIEA) with the Kingdom of the Netherlands, the first TIEA signed by Canada. Get PwC’s analysis of the agreement.
Tax Memo: British Columbia Sales Tax Harmonization BC's minister of finance announced the province will harmonize its sales tax system on July 1, 2010. This PwC Tax Memo analyzes the impact of the announcement on your business.
Tax Memo: Not Just Another Accounting Exercise: Managing Change for the Tax Function While IFRS gives companies with a chance to improve their tax functions, there are tax-related challenges they must consider. This Tax Memo offers ideas within PwC’s Tax Function Effectiveness framework.
Tax Memo: Application of Ontario's Single Sales Tax to New Homes A new Ontario bulletin confirms province's 2009 budget announcement concerning a new single sales tax launch on July 1, 2010. The bulletin introduces rebates, transitional rules and disclosure requirements.
Tax Memo: Tax Incentives for Digital Media in Ontario This PwC Tax Memo provides a brief overview of OIDMTC and chronicles the tax credit program’s key changes.
Tax Memo: 1% Taxable Benefit Rate: Action Required Before July 1, 2009 Read this Tax Memo to learn how the 1% Taxable Benefit Rate can help you.
Tax Memo: Income Trust Conversion Rules Enacted This PwC Tax Memo describes key changes to the tax rules related to converting an income fund into a taxable Canadian corporation.
Tax Memo: Ontario Sales Tax Harmonization Read PwC's industry-specific Tax Memos to learn the impact of the HST on your Ontario-based business and how to plan for transition.
Tax Memo: Ontario Budget 2009 This Tax Memo features Ontario's 2009 budget, presented by the province's Minister of Finance, Dwight Duncan, on March 26, 2009.
Tax Memo: 2009 Quebec Budget The recession has now hit the Québec economy. Read PwC's analysis of the province's 2009–10 budget.
Tax Memo: 2009 Saskatchewan Budget Highlights This PwC Tax Memo discusses the changes announced in the Saskatchewan 2009 budget on Wednesday March 19, 2009.
Tax Memo: The FCA Decision in Prévost Car Inc. This Tax Memo discusses the FCA Decision in Prévost Car Inc.
Tax Memo: 2009 British Columbia Budget: Tax Highlights This PwC Tax Memo shares our analysis of the 2009 B.C. budget.
Tax Memo: Quebec Proposals on Aggressive Tax Planning This Tax Memo summarizes Quebec’s Ministry of Finance’s January 30th, 2009 proposals on aggressive tax planning.
Tax Memo: 2009 Annual Tax Filing and Remittance Deadlines for Corporations This PwC Tax Memo lists the 2009 tax filing and remittance deadlines for Canadian businesses.
Tax Memo: 2009 Federal Budget This PwC Canada Tax Memo discusses the 2009 federal budget. Canada's Minister of Finance, Jim Flaherty, unveiled the budget on Tuesday January 27th, 2009.
Tax Memo: New Supreme Court Ruling on GAAR — Reflections on the Lipson Case Read this Tax Memo for PwC’s analysis of the Supreme Court Ruling on GAAR.
Tax Memo: Important Supreme Court Ruling on GAAR — Highlights This Tax Memo provides an overview of the decision in Jordan B. Lipson, Earl Lipson v. The Queen case.
Tax Memo: Functional Currency Tax Reporting This Tax Memo discusses changes to section 261 of the Income Tax Act.
Tax Memo: Tax-Free Savings Account This Tax Memo discusses the Tax-Free Savings Account, its rules and how it can benefit you.
Tax Memo: Enhancing Canada’s International Tax Advantage Read this summary of the Advisory Panel on Canada’s System of International Taxation recommendations for improving Canada’s international tax system and PricewaterhouseCoopers’ commentary.
Tax Memo: Ontario Property Tax Alert Learn how the new Ontario property tax assessments may affect you and how to get started with your property assessment appeal.
Tax Memo: Canada-US Income Tax Treaty On December 15, 2008, the fifth Protocol (the Protocol) to the Canada-US Income Tax Convention entered into force when Canada and the US notified each other that their respective applicable procedures have been satisfied.
Ontario Corporate Tax Harmonization for Insurance Companies This Tax Memo addresses Ontario corporate tax harmonization issues that affect insurance companies.
Tax Memo: Understanding RESPs This Tax Memo discusses the RESP rules, including the latest changes to these rules. It will help you decide whether an RESP would be a suitable education savings vehicle for your family.
Tax Memo: 2008 British Columbia Economic Plan: Highlights British Columbia’s Economic Plan, delivered on October 22, 2008, includes measures to improve the province’s competitiveness and reduce costs for families and businesses.
Tax Memo: Tax Planning for Income Trust Conversions and Acquisitions This Tax Memo provides detailed comments about certain Canadian income tax issues that are relevant for planning income trust conversions and acquisitions
Tax Memo: Fifth Protocol to the Canada-US Income Tax Treaty: Technical Explanation On July 10, 2008, the US Treasury Department released the Technical Explanation of the fifth Protocol to the Canada-US Income Tax Convention to provide guidance with respect to many questions relating to the application of the Protocol.
Tax Memo: Foreign Affiliate Elections: Deadlines Extended On June 27, 2008, the federal Minister of Finance proposed measures to ease tax compliance for Canadian corporations with foreign affiliates.
Tax Memo: Functional Currency Election: Proposed Revisions and Extended Deadline On June 27, 2008, the Department of Finance issued a news release proposing measures to ease tax compliance for Canadian corporations that report earnings in a foreign currency.
Tax Memo: Bill C-28 Foreign Affiliate Elections -- Approaching Filing Deadline Companies with foreign affiliates could be affected by a number of generally relieving technical amendments to the foreign affiliate rules that became effective after Bill C-28 received royal assent on December 14, 2007.
Tax Memo: Withholding Tax on Interest -- Welcome Changes for 2008 and Beyond Withholding tax on interest paid or credited on debts owing to non-residents may be reduced, and in many cases eliminated.
Tax Memo: International Tax Policy -- April 2008 Consultation Paper The Advisory Panel on Canada’s System of International Taxation issued its consultation paper, Enhancing Canada’s International Tax Advantage, on April 25, 2008.
Tax Memo: Important Court Ruling on Treaty Interpretation -- Another Setback for the CRA The Tax Court of Canada decision in Prévost Car Inc. v. The Queen provides valuable guidance on how receptive the courts are likely to be when the Canada Revenue Agency challenges some international structures.
Tax Memo: 2008 Alberta Budget: Tax Highlights This document contains the highlights of tax measures included in the 2008/2009 Budget of the Government of Alberta, delivered April 22, 2008, by Minister of Finance Iris Evans. (PDF with highlights only.)
Tax Memo: The Move to IFRS: Tax Implications The move to International Financial Reporting Standards (IFRS) from current Canadian Generally Accepted Accounting Principles (Canadian GAAP) will fundamentally change the way Canadian companies report their business results.
Tax Memo: 2009 Manitoba Budget: Tax Highlights Manitoba's Minister of Finance, Greg Selinger, presented the province's 2009 budget on March 25, 2009. Read this Tax Memo for PwC's budget commentary.
Tax Memo: Quebec Budget 2008-2009: Tax Highlights This document contains the highlights of tax measures included in the 2008/2009 Budget of the Government of Québec, delivered March 13, 2008, by Minister of Finance Monique Jérôme-Forget. (PDF with highlights only.)
Tax Memo: 2008 Quebec Budget This document contains the highlights of tax measures included in the 2008/2009 Budget of the Government of Québec, delivered March 13, 2008, by Minister of Finance Monique Jérôme-Forget. (PDF only.)
Tax Memo: 2008 Federal Budget: Highlights This PwC Canada Tax Memo shares highlights from the 2008 federal budget. The country's Minister of Finance, Jim Flaherty, unveiled the budget on Tuesday February 26th. (PDF with highlights only.)
Tax Memo: 2008 Federal Budget Minister of Finance Jim Flaherty presented the minority government’s third budget on February 26, 2008. The budget contains a modest number of tax measures, but no tax rate or bracket changes or other broad-based tax initiatives. (PDF of full commentary only.)
Tax Memo: 2008 Annual Tax Filing and Remittance Deadlines for Corporations In addition to filing annual income and capital tax returns (due six months1 following each taxation year end), canadian corporations may be required to meet several other Canadian annual filing and remittance deadlines.
Tax Memo: 2008 British Columbia Budget As part of British Columbia's 2008-09 budget speech, Finance Minister Carole Taylor announced a number of provincial tax measures for individuals and businesses. (PDF only.)
Tax Memo: Pension-splitting Opportunity for 2007 Income Tax Returns Newly enacted legislation provides seniors and other pensioners a new tax planning opportunity.
Tax Memo: House of Commons Standing Committee on Finance Recommends Tax Changes On February 7, 2008, the House of Commons Standing Committee on Finance released its report, Taxing to Prosper: Canada’s System of Taxes, Fees and Other Charges.
Tax Memo: Reminder -- Two Critical Property Tax Deadlines Approaching Two deadlines are approaching for those who own or lease commercial or industrial properties in Ontario to claim a tax rebate for the 2007 tax year or file a complaint for the 2008 tax year.
Tax Memo: Federal Corporate Tax Rate Reductions Some corporations may be required to record significant adjustments to future tax balances and income tax expense, to reflect corporate tax rate reductions implemented by Bill C-28, which received royal assent on December 14, 2007.
Tax Memo: More Tinkering with the SIFT Rules The Specified Investment Flow-Through rules, originally announced on October 31, 2006, and enacted in June 2007, impose a tax on distributions paid by publicly traded trusts and partnerships.
Tax Memo: Ontario Tax Harmonization Ontario’s corporate income tax and minimum tax will be administered by the Canada Revenue Agency starting with taxation years ending after December 31, 2008.
Tax Memo: 2007 Ontario Economic Outlook and Fiscal Review Brings Tax Relief Ontario’s Minister of Finance, The Honourable Dwight Duncan, presented the province’s 2007 Economic Outlook and Fiscal Review on December 13, 2007. (PDF only.)
Tax Memo: New Tax Era for Private Foundations A Notice of Ways and Means Motion tabled in the House of Commons on November 13, 2007, enhances Canada’s tax incentives for individuals, corporations and trusts that donate publicly listed securities to private foundations, by extending the capital gains exemption to these gifts.
Tax Memo: Functional Currency: Proposed Election On October 2, 2007, Canada’s federal government released legislative proposals to enact certain tax measures first announced in its 2006 budget.
Tax Memo: Draft Legislation Affects Insurers and Other Financial Institutions The Department of Finance released draft legislation on November 7, 2007, that intends to simplify the taxation of entities defined in the Income Tax Act as financial institutions by better aligning the tax rules with the financial instruments accounting standard that came into effect on October 1, 2006.
Tax Memo: 2007 Federal Economic Statement Promises $60 Billion in Tax Cuts Over Six Years PwC shares its response to the federal government's fiscal update on October 30, 2007. (PDF only.)
Tax Memo: Year-End Tax Planner (2007) -- for Individuals and Owner-Managed Businesses Designed for investors and small and large business owners, PwC’s Tax Memo: Year-End Tax Planner (2007) can make your tax planning more efficient and cost-effective.
Tax Memo: Fifth Protocol to the Canada-US Income Tax Treaty -- Reflections This Tax Memo reflects on the effect the Protocol will have on Canadian multinationals with US operations, US multinationals with operations in Canada and on certain individuals.
Tax Memo: Alert for Corporations: Draft Legislation Makes Previously Announced Changes On October 2, 2007, the federal Minister of Finance, the Honourable Jim Flaherty, released an omnibus package of draft tax legislation that contains many personal and corporate changes.
Tax Memo: Canada-US Income Tax Treaty: Fifth Protocol Makes Major Changes On Friday, September 21, 2007, after nearly 10 years of negotiation, the United States and Canada jointly released the fifth Protocol1 (the Protocol) to the Canada-US Income Tax Convention (Treaty).
Tax Memo: Latest CRA Views on the 95(6)(b) Foreign Affiliate Anti-Avoidance Rule: Reflections This Tax Memo reflects on whether the CRA's latest ITTN publication signals a substantive change to previous CRA positions on the interpretation and application of paragraph 95(6)(b) of the Income Tax Act.
Tax Memo: SR&ED Investment Tax Credit Claims: Making the CRA’s Revised Procedures Work Based on new strict guidelines, initial completeness checks and preliminary assessment of SR&ED claims are now carried out by taxation centre staff (rather than the Coordinating Tax Services Office).
Tax Memo: The CRA's Revised Position on SR&ED Contracts The Canada Revenue Agency (CRA) recently revised its position on whether a taxpayer can claim, as a qualified expenditure for Investment Tax Credit (ITC) purposes, amounts paid to placement agencies under a contract to carry out Scientific Research and Experimental Development (SR&ED) work on the taxpayer’s behalf.
