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.
Tax memo: TCDR alert: CRA endorses update of the OECD transfer pricing guidelines (Memo No. 2012-54) This Tax memo outlines the CRA’s acceptance of the OECD’s recent updates to transfer pricing guidelines.
Tax memo: TCDR alert: Referrals to the Transfer Pricing Review Committee – More emphasis on penalty referrals (Memo No. 2012-53) The CRA increased its focus on the transfer pricing penalty referral process.
Tax memo: October 24, 2012 Notice of Ways and Means Motion: Offshore investment fund rules revised (Memo No. 2012-52) This Tax memo outlines the implications of the rules for offshore investment funds (OIFs).
Tax memo: Returning to B.C.’s Provincial Sales Tax: Transitional rules for new housing (Memo No. 2012-51) This Tax memo updates our February 19, 2012, Tax memo “Returning to B.C.’s Provincial Sales Tax: Transitional rules for new housing” to reflect November 2012 announcements.
Tax memo: October 24, 2012 Notice of Ways and Means Motion: “Final” version of non-resident trust rules (Memo No. 2012-50) This Tax memo outlines the implications of the final rules for non resident trusts.
Tax memo: QST harmonization — Draft legislation has important implications for financial services and others (Memo No. 2012-49) This Tax memo outlines key rules and changes related to harmonization of QST with GST, mainly in respect of financial services.
Tax memo: 2013 Quebec budget tax highlights (Memo No. 2012-47) On November 20, 2012, Nicolas Marceau, Quebec Minister of Finance, delivered the 2013/2014 Budget of the Government of Quebec.
2013-2014 Quebec budget The Minister of Finance and the Economy Nicolas Marceau tabled a balanced budget for 2013-2014 on November 20, 2012. “After four years of deficits, Québec will finally have a balanced budget,” he proudly declared.
Tax memo: TCDR alert: CRA issues 2012 annual report on the Canadian Mutual Agreement Procedure (MAP) (Memo No. 2012-46) This Tax memo provides an overview of the findings in the CRA’s annual report on the Canadian Mutual Agreement (MAP) program.
Tax memo: Canada signs treaty with Hong Kong — Good news for cross-border transactions (Memo No. 2012-45) This Tax memo provides an overview of the recently signed Canada-Hong Kong tax treaty.
Tax memo: Ontario’s Interactive Digital Media Tax Credit: Are you benefitting? (Memo No. 2012-44) This Tax memo provides details on Ontario’s Interactive Digital Media Tax Credit.
Tax memo: October 24, 2012 Notice of Ways and Means Motion: Changes to upstream loan and foreign tax credit generator rules (Memo No. 2012-43) This Tax memo will discuss changes made by the NWMM to the upstream loan rules and foreign tax credit generator proposals.
Tax memo: Joint ventures and partnerships: GST/HST and issues for real estate industry (Memo No. 2012-42) This Tax memo highlights certain Goods and Services Tax/Harmonized Sales Tax (GST/HST) and Workplace Safety and Insurance Board (WSIB) issues relevant to those in the real estate and construction industries.
Tax memo: Red Tape Reduction Action Plan – What it means for tax compliance (Memo No. 2012-41) This Tax memo outlines the aspects of the federal government’s Red Tape Action Plan that relate to tax compliance reporting.
Tax memo: Comprehensive income tax package released: Long-awaited foreign affiliate amendments included (Memo No. 2012-40 ) This Tax memo lists the more significant amendments released on October 24, 2012, and provides the history of the foreign affiliate amendments.
Tax memo: Re-implementation of British Columbia Provincial Sales Tax: Transitional rules (Memo No. 2012-39) This Tax memo summarizes rules governing the re implementation of Provincial Sales Tax (PST) in British Columbia.
Tax memo: France’s new filing requirements clarified: Good news for Canadian investment fund managers (Memo No. 2012-38) This Tax memo outlines a French filing exemption that will be welcomed by Canadian investment fund managers.
Tax memo: Supreme Court of Canada releases decision in GlaxoSmithKline transfer pricing case (Memo No. 2012-37) This Tax memo summarizes the transfer pricing implications of the Supreme Court of Canada’s decision in GlaxoSmithKline.
Tax memo: Legislation tabled October 15, 2012: Foreign affiliate dumping and shareholder loan rules (Memo No. 2012-36) This Tax memo outlines key changes to international tax measures introduced in the October 15, 2012 Notice of Ways and Means Motion.
Tax memo: State income tax refund opportunity — Is your Canadian company eligible? (Gillette decision) (Memo No. 2012-35) Action may be required if your Canadian company is entitled to a state tax refund, as a result of a recent court decision.
Tax memo: Employee benefits and executive compensation: Draft legislative proposals released (Memo No. 2012-34) This Tax memo discusses August 14, 2012 draft legislative proposals in respect of employee benefits and executive compensation.
Tax memo: Asset management industry tax issues: France's new filing requirements and Canada's prohibited investment rules (Memo No. 2012-33) This Tax memo explains the implications of changes France’s filing requirement and outlines limited relief from Canadian prohibited investment rules.
Tax memo: August 14, 2012 legislative proposals: Alert for mining companies (Memo No. 2012-32) This Tax memo discusses the August 14, 2012, draft legislative proposals that affect the Canadian mining industry.
Tax memo: FCA decides attribution rule did not apply on sale to trust by capital beneficiary (Sommerer) (Memo No. 2012-30) This Tax memo discusses the FCA’s decision that the income attribution rule in subsection 75(2) did not apply on a fair market value sale of property to a trust by a capital beneficiary of the trust.
Tax memo: August 14, 2012 - Legislative proposals: Important international tax changes (Memo No. 2012-31) This Tax memo outlines key changes to international tax measures introduced in the August 14, 2012 legislative proposals.
Tax memo: August 14, 2012 - Legislative proposals released as consultation draft (Memo No. 2012-29) On August 14, 2012, the Department of Finance released for consultation draft legislative proposals that implement measures included in the March 29, 2012 federal budget.
Tax memo: TCDR alert: CRA policy on access to audit information at the proposal stage of an audit – What to do to get access (Memo No. 2012-28) This Tax memo describes the Canada Revenue Agency’s (CRA's) policy on taxpayer access to CRA audit reports and other documents that support the issuance of a proposal letter. It suggests what to do if an auditor is reluctant to provide this information.
Tax memo: TCDR alert: Competent authority – Protect your rights (Memo No. 2012-26) This Tax memo addresses issues that Canadian taxpayers must be aware of when requesting relief from double taxation other than in respect of the U.S.
Tax memo: TCDR alert: CRA policy on access to audit reports — Informal disclosure should be the norm, not the exception (Memo No. 2012-27) This Tax memo describes the CRA’s stated policy on taxpayer access to CRA audit and appeals reports and other documentation supporting an assessment, and suggests a course of action if the information requested is not forthcoming.
Tax memo: Retailers: Customs is targeting imports of footwear and apparel (Memo No. 2012-25) Retailers who import footwear and apparel should be aware that the Canada Border Service Agency (CBSA) has added these products to its list of priorities for “value for duty” audits.
Tax memo: Sales tax changes — The years ahead (Memo No. 2012-24) Four provinces – British Columbia, Nova Scotia, Quebec and Prince Edward Island – will be modifying their sales tax regimes or rates in coming years.
Tax memo: Nova Scotia HST — Guidance on sales to Indians (Memo No. 2012-23) The Harmonized Sales Tax (HST) in Nova Scotia applies to most taxpayers. However, certain supplies made to Aboriginal persons in Canada are not subject to HST.
Tax memo: Ontario’s “2% surtax” — The bottom line (Memo No. 2012-22) As widely reported, the McGuinty government has agreed to implement a “2% surtax” on individuals with incomes over $500,000. This Tax memo outlines how we expect Ontario’s new high-earner tax to work.
Tax memo: 2012 Federal budget: What does it mean for insurers? (Memo No. 2012-21r) The 2012 federal budget included a number of tax initiatives that are particularly relevant to the insurance industry. These are reviewed in this Tax memo.
2012 Manitoba budget (Memo No. 2012-20) On Tuesday, April 17, 2012, Manitoba’s Minister of Finance, Stan Struthers, presented the province’s 2012 budget. Read our Tax memo to learn moare about the tax measures announced in the budget.
Tax memo: Canadian federal budget targets Canadian subsidiaries of foreign multinationals (Memo No. 2012-18) This Tax memo discusses changes associated with new “foreign affiliate dumping” and thin capitalization proposals introduced in the 2012 federal budget.
Tax memo: Supreme Court of Canada rules on trust residence – St. Michael Trust Corp. v. The Queen (Garron Family Trust) (Memo No.: 2012-19) The Supreme Court of Canada released its decision in St. Michael Trust Corp. v. The Queen (sub. nom. Garron). This Tax memo discusses the details.
2012 Federal Budget: Full commentary Minister of Finance Jim Flaherty tabled the budget on March 29, 2012. Read our analysis to learn about the tax implications for you.
2012 Ontario Budget The 2012 Ontario budget freezes the general corporate income tax rate at 11.5%. Scheduled reductions to this rate are deferred until Ontario’s budget is balanced.
Tax memo: Joint Ventures—CRA ends policy allowing separate fiscal periods: How will this affect your company? (Memo No. 2012-15) A recent Canada Revenue Agency (CRA) announcement may adversely affect real estate companies that carry on projects or hold investment properties through joint ventures.
2012 Quebec Budget The 2012 Quebec Budget does not change the income tax rates of individuals and corporations. New tax credits are introduced for specialized corporations in certain sectors of activities.
2012 Saskatchewan Budget: Tax highlights On March 21, the Honourable Ken Krawetz, the Minister of Finance in Saskatchewan tabled the budget. Read our analysis of the budget to learn more about tax changes introduced for both individuals and corporations.
2012 Quebec Budget - Highlights The 2012 Quebec Budget does not change the income tax rates of individuals and corporations. New tax credits are introduced for specialized corporations in certain sectors of activities.
Tax memo: TCC rules against Morguard Corporation – Break fee was fully taxable as an income receipt (Memo No. 2012-11) This Tax memo discusses the TCC’s decision in Morguard—the first case to consider the tax consequences of a break fee from the recipient’s perspective.
Tax memo: Changes to partnership returns – What they mean for you (Memo No. 2012-10) This memo examines recently announced revisions to the CRA’s expanded information requirements for partnership returns. Learn about the revisions to T5013 SCH 50.
Tax memo: TCC rules in favour of Velcro Canada — Beneficial ownership for tax treaty purposes (Memo No. 2012-09) On February 24, 2012, the Tax Court of Canada released a decision on the Velcro Canada case, which is only the second case to consider the meaning of “beneficial owner.”
Tax memo: 2012 British Columbia budget — tax highlights (Memo No. 2012-07) The 2012 BC budget changes certain income tax rates, both corporate and personal and introduces a number of new tax credits. Read our Tax memo to learn more.
Tax memo: Eliminating the HST in British Columbia — Canada’s Department of Finance proposes transitional rules (Memo No.: 2012-06) This tax memo discusses the details of transitional rules relating to the elimination of the HST in British Columbia.
Tax memo: Returning to B.C.’s Provincial Sales Tax — Transitional rules for new housing (Memo No.: 2012-05) This Tax memo outlines transitional rules introduced by British Colombia to mitigate potential double taxation on new housing, as a result of the return to the 7% Provincial Sales Tax (PST).
Tax memo: CRA risk assessment audit approach – What it can mean for your corporation (Memo No.: 2012-04) 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) (Memo No.: 2012-03) 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: 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: 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.
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 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 – 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: 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: 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.