Tax Publications

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Tax Insights: GST/HST reporting for the real estate sector: Are you compliant?
The Canada Revenue Agency is auditing the GST/HST reporting of taxpayers in the real estate sector.

The big table: Film and video incentives in Canada 2014
Canada has numerous tax incentives for companies that develop film, video and digital content, including video games. For help understanding these incentives, navigate the interactive maps and read PwC’s big table publications.

Insurance industry – Key tax rates and updates (2014)
Tax changes, rates, deadlines and other useful information for the insurance industry in Canada.

Tax Insights: More changes to Form T1135, ‘Foreign Income Verification Statement’
The CRA has announced changes for taxpayers required to file Form T1135, ‘Foreign Income Verification Statement.’

Commodity Clips, 2014 Issue 2
This edition of Commodity clips describes recent commodity tax developments.

2014 Ontario budget: Higher taxes for higher earners and some corporations
On July 14, 2014, Ontario’s Minister of Finance, Charles Sousa, presented the majority government's budget. The July 14, 2014 budget reintroduces the tax measures proposed in the province’s May 1, 2014 budget.

Tax Insights: GST/HST pension plan compliance obligations
This Tax Insights discusses Goods and Services Tax/Harmonized Sales Tax compliance issues relevant to employers that have registered pension plans.

In Print: BEPS and Indirect Tax
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.

Tax facts and figures: Canada 2014
Our Tax facts and figures: Canada 2014 convenient reference guide includes Canadian individual and corporate tax rates and deadlines, summaries of recent tax cases and a wide range of other valuable tax information.

Tax Insights: Structuring a partnership: CRA attacks GST/HST-exempt treatment of partnership distributions
Incorrectly structuring the activities of a partnership can cause GST/HST deeming rules to apply; resulting in a GST/HST liability for person’s involved in the partnership’s business.

Corporate Tax Rates and Legislation: Tax Management and Accounting Services
This quarterly update discusses developments related to the accounting for income taxes.

Tax Insights: New IRS relief for US citizens living outside the US
On June 18, 2014, the US Internal Revenue Service announced changes to its offshore voluntary compliance programs that are expected to significantly increase the number of US persons that can participate in these programs.

“Top global mobility issues facing Tax Directors” series — Tax equalization costs
In this final episode of our “Top global mobility issues facing Tax Directors” series, Candace Doig outlines the concept of tax equalization.

Tax Tracks Episode 67: “Top global mobility issues facing Tax Directors” series — Non-resident director fees
In this episode of our “Top global mobility issues facing Tax Directors” series, Nupur Rishi looks at the taxation of non-resident director’s fees.

Global FS tax newsflash: EU FTT – EU-10 come together with further statement of political intent
The spotlight returned to Brussels on May 6, 2014, as observers awaited an update on the latest developments on the EU Financial Transaction Tax at the ECOFIN meeting of finance ministers.

Tax Insights - June 2014 Quebec budget
The Minister of Finance Carlos Leitao, tabled a budget mainly aimed at economic recovery and restoring sound public finances.

Tax Insights: June 2014 Quebec budget – Tax highlights
Carlos Leitao, Quebec Minister of Finance, delivered today, June 4, 2014, the 2014/2015 Budget of the Government of Quebec.

May 2014 - Topical immigration issues affecting your global business
This audio recording of an HRS breakfast seminar provides an overview of corporate immigration requirements, with a focus on Canadian and US cross-border travel. It outlines key strategies and information to facilitate successful cross-border movement.

Tax Tracks Episode 66: “Top global mobility issues facing Tax Directors” series – Foreign pension plans
Our 'Top global mobility issues facing Tax Directors' series continues with Brandi Scales discussing foreign pension plans.

Tax Insights: GST/HST issues affecting the real estate and construction industries
This Tax Insights highlights Goods and Services Tax/Harmonized Sales Tax (GST/HST) issues relevant to the real estate and construction industries.

Top global mobility issues facing tax directors - A seven-part Tax Tracks podcast series
This podcast series is designed to provide Canadian corporate tax teams with a high-level understanding of issues impacting mobility programs to help them identify relevant corporate tax issues and areas of most risk.

Tax Insights: Alert for multinational companies: Payroll and immigration compliance
Cross-border employee travel into Canada raises various Canadian tax withholding and immigration compliance requirements. Multinational companies should consider whether they have the processes and controls in place to manage these requirements and the associated risks.

Tax Insights: Federal Court rules on 95(6)(b) in Lehigh
On April 23, 2014, the Federal Court of Appeal (FCA) released an important decision on the scope of paragraph 95(6)(b), an anti avoidance rule found in the part of the Income Tax Act that governs the tax treatment of ‘foreign affiliates’ of Canadian corporations.

Tax Tracks Episode 65: “Top global mobility issues facing Tax Directors” series — Deferred compensation arrangements
Our “Top global mobility issues facing Tax Directors” series continues with Kin Ngan discussing deferred compensation arrangements.

Corporate Tax Rates and Legislation: Q1 2014 Accounting Status
This quarterly update discusses developments related to the accounting for income taxes.

Commodity Clips, 2014 Issue 1
This edition of Commodity clips describes recent commodity tax developments.

Tax Insights: Tax Court of Canada finds corporate reorganization abuses section 84.1
In a judgment (Descarries) rendered on March 7, 2014, under the Informal Procedure, the Tax Court of Canada provided an example of a situation where, in the Court’s view, the object and spirit of section 84.1 had been abused, triggering the application of the general anti-avoidance rule (GAAR).

Tax Tracks Episode 64: “Top global mobility issues facing Tax Directors” series – Intercompany equity charge-back agreements
In this episode of our ‘Top global mobility issues facing Tax Directors’ series, Vasu Krithigaivasan discusses equity charge-back agreements that commonly exist between a Canadian subsidiary and its foreign parent company.

Being strategic in resources: JVs remain key - Global mining deals outlook / March 2014
Joint Ventures (JVs) have been an important part of the mining industry for decades and have been instrumental to the development of many major resource projects.

February 2014: Foreign reporting requirements in Canada and the US: What’s new and why you need to comply
Recently, tax jurisdictions have increased their reporting requirements for taxpayers holding offshore property and financial accounts. Combined with increased scrutiny, accurate reporting of these assets is becoming even more essential.

Tax Tracks Episode 63: “Top global mobility issues facing Tax Directors” series – Frequent business travellers
In the second episode of our “Top global mobility issues facing tax directors” series, Edmond Kwan discusses the importance of companies being aware of the travel patterns of their mobile employees.

2014 Manitoba budget: Tax highlights
On March 6, 2014, Manitoba’s Minister of Finance, Jennifer Howard, presented the province’s budget.

January 2014: International assignment basics: Planning for successful assignments abroad
This 60 minute webcast by PwC’s Human Resource Services practice explores the potential hazards for companies or individuals that are new to the realm of global mobility, or those looking to enhance their current processes.

Tax Insights – Estate tax update: Canadians living in the United States
This Tax Insights explains how the United States determines U.S. residency for estate and gift tax purposes.

Tax Insights: Foreign Income Verification Statement (Form T1135) – Transitional rules announced
Taxpayers required to file Form T1135, Foreign Income Verification Statement, must include additional information on foreign property, starting for taxation years ending after June 30, 2013.

In Print: Financial Sector Spending Surge – New Project Needs
The federal government is pondering some welcome GST changes that can help those who provide outsourcing services to the financial sector.

Tax Insights – Estate tax update: Canadians transferred to the US
U.S. estate, gift and generation-skipping transfer tax exposure for Canadians transferred to the United States.

Tax Insights – Estate tax update: US family members in the Canadian family-owned business
Estate and will planning implications for U.S. family members of Canadian family-owned businesses.

Tax Insights: 2014 federal budget: The demise of immigration trusts
Canada’s February 11, 2014 federal budget proposes to eliminate the tax benefits of immigration trusts. If you have relocated to Canada, this change could have adverse tax consequences.

Tax Insights: 2014 Quebec budget
Budget 2014-2015 confirms a return to fiscal balance in 2015-2016.

Tax Insights: 2014 Quebec budget – Tax highlights
Nicolas Marceau, Quebec Minister of Finance, delivered today, February 20, 2014, the 2014-2015 Budget of the Government of Quebec.

Tax Insights: Bare trusts, nominees and joint ventures: Temporary administrative leniency
A recent Canada Revenue Agency announcement grants taxpayers a temporary reprieve for a bare trust or nominee that reports the Goods and Services Tax/Harmonized Sales Tax on behalf of the members of a joint venture.

Tax Insights: 2014 British Columbia budget - Tax highlights
On February 18, 2014, British Columbia’s Minister of Finance, the Honourable Michael de Jong, presented the province’s budget.

Tax Insights: British Columbia unveils its liquefied natural gas (LNG) tax
Today, British Columbia’s budget unveiled its much-anticipated liquefied natural gas (LNG) tax regime.

Tax Insights: Estate tax update – Owning a US vacation home
If you are a Canadian resident who owns US real estate, learn about your potential estate tax liability and how to reduce it.

Tax Insights: 2014 Annual tax filing and remittance deadlines for corporations
This Tax Insights outlines some of the more common corporate compliance requirements to be considered at this time of year.

Tax Insights: 2014 Federal budget: How it affects you and the charitable and not-for-profit sector
This Tax Insights considers proposals in Canada’s February 11, 2014 federal budget that affect the charitable and not-for-profit sector.

In print: Canadian taxpayers are facing aggressive audits by CRA
Canadian taxpayers face a changing transfer pricing environment, emphasized by BEPS mandate of the OECD, while continuing to manage aggressive CRA audits in respect of transfer pricing issues, and procedural and timing aspects of the audits themselves. This article reviews these issues and related transfer pricing developments in 2013.

Car expenses and benefits: A tax guide and employee log (2014)
Using a vehicle for business means you face an intricate set of tax laws when it comes to claiming your expenses. Find out how you can take advantage of certain tax deductions in this annual guide, summary and employee log.

Tax Insights – Estate tax update: US estate tax exposure for Canadians
This Estate tax update considers the exposure of Canadian residents to US estate tax.

Tax Insights – Estate tax update: US estate tax exposure for US citizens living in Canada
The interaction of U.S. and Canadian tax rules can have important implications for U.S. citizens living in Canada.

2014 Federal budget: More tightening, few tax breaks
Read our analysis of the 2014 federal budget to learn about the tax implications for you.

Section 871(m) regulations webinar: Withholding on dividend equivalents
The new regulations under section 871(m) of the Internal Revenue Code, concerning the imposition of US federal withholding tax on certain equity-linked instruments, raises many issues for Canadian financial services companies.

Global IRW Newsbrief: Canada and the US sign FATCA Intergovernmental Agreement
The United States and Canada announced on February 5, 2014, that they have signed an Intergovernmental Agreement (IGA) to improve international tax compliance and to implement the US Foreign Account Tax Compliance Act (FATCA). The IGA must be ratified under Canadian laws before it comes into force.

Tax Insights: Trust loss restriction rules: Implications for funds and asset managers
Newly enacted trust loss restriction rules may have unintended and adverse tax implications for investment funds established as trusts.

Digging deeper into all-in cost disclosure - Mining's new frontier
Investors and analysts are increasingly calling for a more complete and transparent disclosure of total costs of production in the mining industry as margins have been squeezed by the recent decline in commodity prices.

Tax Insights: New regulations for passive foreign investment companies: What they mean for Canadian mutual fund owners
Temporary and final regulations recently issued by the Internal Revenue Service (IRS) and Treasury Department provide guidance for owners of passive foreign investment companies (PFICs).

Tax Tracks Episode 62: “Top global mobility issues facing Tax Directors” series – Cross border employment structures
This first episode in the ‘Top global mobility issues facing Tax Directors’ series discusses the need for Tax Directors to be engaged in the structuring an international work assignment.

December 2013: Temporary away from home rules: Comparing and contrasting Canadian regulations with other common expat locations
This 60 minute webcast by PwC's Human Resource Services practice compares and contrasts the tax treatment of these expenses or allowances between Canada and common expat locations.

Corporate Tax Rates and Legislation: Q4 2013 Accounting Status
This quarterly update discusses developments related to the accounting for income taxes.

Transforming the Tax Function
The tax function is often overlooked as an area for improvement. Shining a light on this area can reveal untapped opportunities where updates in technology, process, people, and/or data can lead to benefits for the broader business.

Commodity Clips, 2013 Issue 4
This edition of Commodity clips describes recent commodity tax developments.

Tax Insights: BEPS – Where are we?
This Tax Insights updates you on the status of BEPS and what to expect, and helps you deal with the changing environment.

September 2013: New UK legislation leads to a ‘perfect storm’ for employers
This audio recording of an HRS breakfast seminar provides an overview of significant legislative changes in the UK that impact payroll, residency, and reporting and remittance considerations for short-term, long-term and permanent assignments.

Operationalize your tax strategy: Tax Operations Manager
The tax function is often overlooked as an area for improvement. Shining a light on this area can reveal untapped opportunities where updates in technology, process, people, and/or data can lead to benefits for the broader business.

Tax Insights: Taxable benefit rate declining to 1%: Don’t act until January 1, 2014
The federal prescribed interest rate for taxable benefits will decrease to 1% on January 1, 2014. The rate – which is subject to change every quarter – is currently 2%. To lock in the 1% rate and save tax, you must not act until January 1, 2014.

Canadian mining taxation 2013
This publication provides guidance from the industry leaders on the complexities of mining taxation in Canada. Covers all project stages – from exploration to production – to help you manage your tax risks.

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.

Innovation surge sparks oil sands opportunities
Innovation is creating opportunities in Canada's oil sands industry. Oil sands executives and associations share their views in our report. A Chinese version of this report is also available.

创新浪潮 - 点燃油砂业机遇 (Technology in the Oil Sands - Chinese Version)
加拿大的油砂为世界提供了长期、稳定的 能源来源,也将成为供应世界日趋增长的 石油产品需求的重要来源,尤其是在亚洲 经济迅速发展的情况下。我们的报告旨在说明能 使之实现的非常规途径。

In print: It’s 11 pm. Do you know how much GST cost your portfolio is bearing?
This In print sheds light on the rising GST cost of investing.

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.

In print: Are you ready for the upstream loan rules?
In addition to an overview of the new upstream loan provisions, this article by Ken Buttenham, a partner in our Toronto office, provides a framework for determining when they will apply, highlights inherent uncertainties in the legislation and offers suggestions for dealing with the new rules.

Corporate Tax Rates and Legislation: Q3 2013 Accounting Status
This quarterly update discusses developments related to the accounting for income taxes.

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.

Commodity Clips, 2013 Issue 3
This edition of Commodity clips describes recent commodity tax developments.

Global FS tax newsflash: From CRD IV to country-by-country tax reporting for all large companies and groups?
CRD IV: For banks and in place for 2014 - capital management, bonus caps, corporate governance and transparency, including country-by-country tax reporting. There is much about CRD IV that is critical for banks to understand and for financial services to take note of. This Newsflash looks at the country-by-country reporting (and auditing) aspects.

Global FS tax newsflash: OECD’s BEPS paper released. Not aimed at financial services… but clear implications…
The OECD's BEPS project is not primarily directed at the FS sector. However, there are various measures and work streams proposed that cause issues that are of very considerable interest - and application - to FS businesses.

Global IRW Newsbrief: Implementation of the International Tax Compliance (United States of America) Regulations 2013 – Guidance Notes
On August 14, 2013, HM Treasury and HMRC issued updated Guidance Notes in respect of the Implementation of The International Tax Compliance (United States of America) Regulations 2013 laid before the UK House of Commons earlier this month. This version of the guidance supersedes any versions previously published.

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.

Global IRW Newsbrief: The International Tax Compliance (United States of America) Regulations 2013 effective on September 1, 2013
On August 7, 2013, HM Treasury and HMRC laid the International Tax Compliance (United States of America) Regulations 2013 (UK Regulations) before the UK House of Commons. This Newsbrief identifies key changes and certain additions from the proposed UK Regulations which were released in May 2013.

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: 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: 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 Tracks Episode 61: Soft-Moc Federal Court of Canada decision
In this episode we discuss the Soft-Moc case: what led to the dispute, the Federal Court of Canada's decision, and what you can do to help prevent this from happening to your organization.

Tax Tracks Episode 60: Will your foreign-based transfer pricing documentation withstand CRA scrutiny?
In this episode of Tax Tracks, we examine what could happen when a Canadian company’s foreign parent prepares its transfer pricing documentation. To ensure this documentation withstands CRA scrutiny, it should be reviewed to ensure that it meets Canadian standards.

May 2013: Foreign pension plans: Impact on Canadian companies and their employees
This webcast examines the implication to your company and its employees of participating in foreign pension plans.

PKN Alert: OECD base erosion and profit shifting project – update on transfer pricing issues
This PKN Alert provides the highlights and our initial comments on the proceedings.

Global IRW Newsbrief: US government announces six-month extension to FATCA effective dates
The IRS and the US Department of the Treasury issued Notice 2013-43 announcing revised timelines for implementing various provisions under FATCA.

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.

Investing in Canada: Providing expertise to assist foreign investors with the requirements of the Investment Canada Act (ICA) – Canadian Net Benefit Test
The Investment Canada Act (ICA) outlines provisions for reviewing foreign investments in the Canadian mining sector, as well as framework criteria for assessing whether such investment is likely to be of “net benefit” to Canada.

Corporate Tax Rates and Legislation: Q2 2013 Accounting Status
This quarterly update discusses developments related to the accounting for income taxes.

Global FS Tax Newsflash: EU FTT – Will the Commission’s proposal survive?
This Global FS Tax Newsflash provides an update on what continues to be a highly political topic.

Global FS Tax Newsflash: The Italian FTT – deferral of key dates
It was announced in Italy that key dates for payment of the tax and the start of the derivatives regime would be deferred.

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.

SR&ED Tax clip: 2013 Provincial and territorial R&D tax credits (June 20, 2013)
Summary of rules for provincial and territorial R&D tax credits.

SR&ED Tax clip: Federal investment tax credits for R&D and property: 2011 - 2013 (June 20, 2013)
Read our summary of federal investment tax credits for R&D and property for 2011 - 2013.

Global IRW Newsbrief: Draft FATCA-related IRS forms: A snapshot of those released so far
Preparation for compliance with FATCA is well underway and a key element will be the various forms used to communicate between withholding agents, their payees, and the Internal Revenue Service (IRS).

Global IRW Newsbrief: European Commission seeks to expand automatic information exchange between EU Member States
European Union Tax Commissioner Algirdas Šemeta on June 13, 2013 presented a Proposal for a Council Directive intended to combat tax evasion by expanding the scope of the automatic exchange of information between EU Member States.

Tax Tracks Episode 59: “What if" series — Significant tax implications to Canadian residents working for a US employer in Canada
In this episode of Tax Tracks, PwC’s Linda Lee discusses the payroll obligations for US employers with Canadian employees working in Canada and the repercussions for the Canadian employees.

In print: Regulation 105 and Regulation 102 Tax Withholdings: Challenges and Potential Improvements
This In print addresses challenges created by the current withholding regime in the Income Tax Act and regulations 105 and 102, from the joint perspectives of a tax advisor and a taxpayer

Global IRW Newsbrief: HM Treasury and HMRC release details outlining the implementation of FATCA in the UK
This Newsbrief identifies key changes from the draft UK Regulations released in December and highlights relevant aspects of the associated Guidance Notes.

Commodity Clips, 2013 Issue 2
This edition of Commodity clips describes recent commodity tax developments.

Global IRW Newsbrief: BMF announces the release of the German Intergovernmental Agreement for implementing FATCA
This Newsbrief provides an overview of the key elements of the German-U.S. IGA and how it compares to the Model 1 IGA.

Global FS tax newsflash: UK’s challenge blocked for now but UK Treasury indicates they will not let it be
In April 2013, the UK launched a legal challenge against the introduction of an EU Financial Transaction Tax under the Enhanced Cooperation Procedure. On May 31, 2014, the Court of Justice of the European Union released its decision on the UK’s challenge.

Tax Tracks Episode 58: “What if" series – Significant tax implications to Canadian residents working for a US employer in the US
In this episode of Tax Tracks PwC’s Vasu Krithigaivasan discusses the payroll considerations and payment of travel expenses for Canadian residents working in the US for a US employer.

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 Tracks Episode 57: “What if” series – Payroll issues for cross-border employees receiving incentive compensation
In this episode of Tax Tracks, David de Souza discusses payroll issues for cross-border employees related to incentive compensation.

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.

Global IRW Newsbrief: The widespread reach of FATCA: How will it affect your business?
Understanding the impact of FATCA and the path forward for non-financial multinational businesses.

Tax Tracks Episode 56: “What If” series – Payroll issues with respect to expatriate’s stock option grants
In this episode of Tax Tracks, Carola Trolley explores payroll issues with respect to expatriate’s stock option grants.

Global BCM tax newsflash: Federal Administrative Court decision on beneficial ownership in equity finance transactions
This Newsalert draws your attention to the third Federal Administrative Court decision related to the definition of beneficial ownership from a Swiss withholding tax perspective in the case of derivative transactions.

Global IRW Newsbrief: New FATCA guidance for qualified intermediary, withholding foreign partnership, and withholding foreign trust applicants
The Internal Revenue Service (IRS) released important guidance on its website for entities that are classified as foreign financial institutions (FFI) under the provisions of the Foreign Account Tax Compliance Act (FATCA) and considering applying for qualified intermediary (QI), withholding foreign partnership (WP), or withholding foreign trust (WT) status.

Global FS tax newsflash: Legal challenge to the EU FTT – what happens now?
Recently, the UK launched a legal challenge against the EU Financial Transaction Tax (FTT). The UK has received support for its challenge from Luxembourg.

Tax Tracks Episode 55: Transfer Pricing Memo 14 - The CRA endorses OECD revisions
In this episode of Tax Tracks, Joanne Hawley discusses the November 2012 Transfer Pricing Memo – TPM 14

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.

Global IRW Newsbrief: IRS releases draft FATCA registration forms and additional information regarding FFI lists
The Internal Revenue Service (IRS) released draft Form 8957, Foreign Account Tax Compliance Act (FATCA) Registration, for public review and comment on April 5, 2013.

Global IRW Newsbrief: New multilateral action to combat tax evasion
On April 9, the Government of the United Kingdom announced an agreement with France, Germany, Italy and Spain to develop and pilot multilateral tax information exchange arrangements.

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.

Global FS tax newsflash: Italian FTT – Latest developments
This Global FS tax newsflash provides an update on the latest Italian FTT developments.

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.

Global IRW Newsbrief: Applying FATCA to captive insurance arrangements: Surprising results may occur
A captive insurance company is an example of an entity that can produce surprising results when the FATCA rules are applied - affecting both the captive and other entities involved in the arrangement.

March 21, 2013 Federal Budget: How it affects you and the charitable and not-for-profit sector
Brenda Lee-Kennedy and Audrey Diamant share highlights from the federal budget related to charities, other not-for-profit entities and charitable giving.

The Insurance Industry and FATCA – Moving from assessment to implementation: Top 13 in ‘13
Highlights 13 key areas to concentrate on through the remainder of 2013 as you move your FATCA Program from impact assessment into implementation.

Wealth and tax matters
This edition includes eight articles relevant to private businesses, executives and Entrepreneurs.

Global BCM tax newsflash: The latest tax and regulatory developments on the Capital Requirements Directive IV
The “CRD IV” package focuses on capital requirements for banks and investment firms but also includes tax transparency requirements for banks.

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.

February 2013: Engaging an independent contractor? It's more complicated than you think!
Engaging an independent contractor or a self-employed individual is becoming more common as an alternative source of talent. However, complexities can arise in the determination of their status as an employee or an independent contractor.

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.

Global FS tax newsflash: Impact of EU Financial Transaction Tax on the asset management industry
This Global FS tax newsflash considers the impact of the European Union Financial Transaction Tax (FTT) on the asset management industry.

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.

SR&ED Tax clip: 2012 Provincial and territorial R&D tax credits – Updated for Quebec's November 20, 2012 budget (March 12, 2013)
Canada offers one of the most favourable packages of R&D tax incentives among the major industrialized countries. This SR&ED Tax Clip provides a summary of rules for provincial and territorial R&D tax credits.

Global tax accounting services (TAS): Tax Management and Accounting Services
This publication discusses a variety of accounting and reporting developments and the related tax accounting considerations.

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.

Global FS tax newsflash: TRACE Implementation Package announced by the OECD
After years of discussions, the Committee on Fiscal Affairs of the OECD approved the Treaty Relief and Compliance Enhancement (TRACE) Implementation Package. It is an important development in the exchange of information across governments.

Global IRW Newsbrief: How do the final FATCA regulations affect asset managers?
Highlights key areas for consideration for asset managers (including notable changes from the proposed FATCA regulations).

Global IRW Newsbrief: How do the final FATCA regulations impact insurers?
The final regulations relating to the provisions of the Foreign Account Tax Compliance Act (FATCA).

Global IRW Newsbrief: Switzerland and the United States sign a FATCA Intergovernmental Agreement
On February 14, 2013, Switzerland and the United States signed an intergovernmental agreement (Swiss/US IGA) concerning the implementation of FATCA in Switzerland.

Commodity clips, 2013 Issue 1
This edition of Commodity clips describes commodity tax developments in the last two months.

Global FS tax newsflash: EU Commission adopts its new proposal for an EU Financial Transaction Tax
The European Commission today presented its “new” draft proposal for a Council Directive implementing a financial transaction tax (FTT) in 11 countries.

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.

Global IRW Newsbrief: Final FATCA regulations issued: let the compliance begin
The Internal Revenue Service issued comprehensive final regulations implementing the information reporting and withholding tax provisions.

Tax Tracks Episode 54: Change in position on allocation of cross-border stock option benefits
In this episode of Tax Tracks Chantal McCalla discusses the recent changes to the allocation of stock option income accepted by the CRA.

Global FS tax newsflash: OECD Report on Base Erosion and Profit Shifting (BEPS)
A recently released OECD report will have important implications for the financial services sector. The report stems from the concern that corporate tax planning activities result in substantial lost tax revenues.

Global FS tax newsflash: Italian FTT - the draft Decree: do we now have all the answers?
Italy's Minister of Economy and Finance has provided guidance on the scope of the Italian Financial Transaction Tax (FTT), the computations and who will be responsible for collecting and reporting the tax.

2012 in Review: Canadian Tax Highlights
2012 included some significant changes and important tax case law decisions. Our timeline provides an overview.

2013 in Review: Canadian Tax Highlights
Our timeline provides an overview of the important changes and tax law updates that occurred in 2013.

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.

Global FS tax newsflash: Green light for EU Financial Transaction Tax Industry: financial services
This Global FS tax newsflash provides an update on the proposed European Union financial transactions tax.

In print: The foreign affiliate dumping proposals – A perspective from a member of the Advisory Panel on Canada’s system of international taxation
In this article, the author, a member of that Panel, provides background to the Panel’s recommendation behind the proposals and views on the appropriateness of the proposals.

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.

Global FS tax newsflash: Latest developments on the EU Financial Transaction Tax – deciphering the Brussels labyrinth
The January 1, 2014 planned implementation date for adopting the EU Financial Transaction Tax likely will be delayed and there are good opportunities for lobbying to shape the proposed FTT regimes.

Global tax accounting services (TAS): Around the world – When is a tax law enacted or substantively enacted?
This publication provides a summary based on our understanding of each jurisdiction's current laws, governing procedures and practices.

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 Management and Accounting Services: Corporate tax rates and legislation—Status for accounting purposes (December 31, 2012)
This quarterly update discusses developments related to the accounting for income taxes.

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.

Global FS tax newsflash: Financial transaction taxes — the Italian FTT takes shape
This Global FS tax newsflash discusses the key provisions in Italy's FTT amendment.

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.

Commodity clips, 2012 Issue 6
This edition of Commodity clips describes commodity tax developments in the last two months.

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 Tracks Episode 53: Frequent Business Traveller Issues: Voluntary Disclosure
In the final episode of our “Frequent Business Traveller” series, Jennifer Sinstead focuses on the Canadian Revenue Agency’s Voluntary Disclosure Program.

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.

Global FS tax newsflash: France issues guidance for foreign investment funds to reclaim withholding taxes
The French government has provided detailed guidance on how foreign investment funds can obtain refunds of French WHT.

Tax Tracks Episode 52: Frequent Business Traveller Issues: Corporate, Regulatory and Governance Issues
In the third episode of the “Frequent Business Traveller” series, Brandi Scales explores the risks companies and individuals face through cross-border travel.

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.

Global FS tax newsflash: Financial transaction tax update – EU ministers consider Enhanced Cooperation on FTT
Eleven EU member states are moving rapidly towards agreement on the introduction of an FTT, which is likely to start January 2014.

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: 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.

Frequent Business Traveller Issues: A four-part Tax Tracks podcast series
Frequent business travellers and their employers face a number of tax issues and this four-part podcast series examines some of these challenges.

Tax tracks Episode 51: Frequent Business Traveller Issues: Employer and Employee Compliance Issues
In the second episode in our “Frequent Business Traveller” series Shabnam Malik provides insight into compliance issues facing non-resident employees & employers.

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 Tracks Episode 50: Frequent Business Traveller Issues: An Intro
In the first episode of our “Frequent Business Traveller Issues” series, Chris Chan gives an overview of the tax obligations of the employer and employee.

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.

SR&ED Tax clip: Federal investment tax credits for R&D and property: 2011 - 2012 (October 12, 2012)
Read our summary of federal investment tax credits for R&D and property for 2011 - 2012.

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.

Year-end tax planner – 2013: Helping individuals and owner-managed businesses save tax
The Year-end tax planner is designed primarily for individuals who have accumulated some wealth or own their own businesses (large or small). It includes year-end tax planning checklists.

Global FS tax newsflash: Financial transaction tax – Commission gives green light for Enhanced Cooperation
Ten participating EU Member States get the green light to create a common FTT system.

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.

Global FS tax newsflash: Proposed Italian and Portuguese FTTs
Although Italy and Portugal have pledged to support an EU-wide FTT, they are both taking steps to introduce national legislation.

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.

Global FS tax newsflash: Green light for EU FTT under enhanced cooperation
An 'EU-wide' financial transactions tax (FTT) is likely to become effective January 1, 2014.

Commodity clips, 2012 Issue 5
This edition of Commodity clips describes commodity tax developments in the last two months.

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.

Global FS tax newsflash: Germany and France push for EU financial transactions tax
Germany and France encourage EU Member States to adopt an EU financial transactions tax.

Tax Management and Accounting Services: Corporate tax rates and legislation—Status for accounting purposes (September 30, 2012)
This quarterly update discusses developments related to accounting for income taxes.

Global FS tax newsflash: Spanish Financial Transactions Tax proposed
This Global FS tax newsflash discusses our views on proposals for a Spanish Financial Transactions Tax.

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.

Oil and Gas Taxation in Canada - Framework for investment in the Canadian oil and gas sector
This publication summarizes the way in which Canadian oil and gas operations are taxed by the Canadian federal and western provincial governments.

加拿大石油与天然气税制
本文总结了加拿大联邦政府及其西部省份对加拿大石油与天然气业务的征税方式。

Developments: Legislative proposals confirm SR&ED changes
Despite extensive industry feedback to reconsider or delay the SR&ED measures introduced in the 2012 federal budget, the Department of Financed has moved to implement them.

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: 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: 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: 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.

Commodity clips, 2012 Issue 4
This edition of Commodity clips describes commodity tax developments in the last two months.

Global FS tax newsflash: The EU financial transactions tax — unprecedented steps
It appears likely that a Financial Transactions Tax will be implemented in a number of European countries through the European Union’s enhanced cooperation procedure.

Billing Transformation
Our team works collaboratively with you to address critical billing issues and has assisted clients with transformational initiatives ranging from billing process improvements to new system implementations.

Claims Transformation
Our Claims Transformation team can help you define and implement the right claims operations strategy and operational model to help you achieve your business objectives.

Distribution and Channel Management Transformation
Our team can help transform your organization by advising on the design and execution of your distribution and channel models to deliver a targeted, consistent, and brand-aligned customer experience.

Policy Administration Transformation
Our Insurance team helps you make the right decisions regarding policy administration. We bring the skills and know-how of a global network of insurance professionals who have dealt with issues like those faced by your company and can provide an independent point of view.

Tax Management and Accounting Services: Corporate tax rates and legislation—Status for accounting purposes (June 30, 2012)
This quarterly update discusses developments related to the accounting for income taxes.

Tax Tracks Episode 49: "What if" series - Dealing with “sticky” situations with the CRA - part 2
In this episode of Tax Tracks, we continue our “What if...” podcast subseries with Sharon Gulliver, who discusses further hypothetical situations taxpayers may find themselves in with the CRA.

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.

Global FS tax newsflash: Seminal European Court ruling on the illegality of some European withholding taxes
A recent European court case has potential implications for any foreign investor in EU equity investments and therefore will be of wide interest.

Commodity clips, 2012 Issue 3
This edition of Commodity clips describes commodity tax developments in the last two months.

In print: Beneficial ownership as a treaty anti-avoidance tool?
In this article, the authors first canvass the history of the beneficial ownership concept in tax treaties and then discuss the recent CRA and OECD attempts to broaden the rule.

Tax Tracks Episode 48: Best Practices in Transfer Pricing
In this episode of Tax Tracks, Andy McCrodan talks about important Transfer Pricing practices and the consequences of not having proper controls in place.

Tax Tracks Episode 47: "What if" series - Dealing with “sticky” situations with the CRA
Read this podcast transcript for help with tax audit preparation and how to effectively dealing with the CRA. Or visit www.pwc.com/ca/taxtracks to listen to the episode.

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: 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.

Entertainment and Media Tax Clip: New Brunswick's multimedia funding initiative replaces the film tax credit (April 5, 2012)
New Brunswick's Multimedia Initiative, a funding support program for the province's film, television and new media industry, has replaced its Film Tax Credit.

In Print: Foreign Affiliate Dumping
The March 2012 federal budget introduced a new rule that significantly restricts a Canadian subsidiary owned by a foreign corporation from investing in a foreign affiliate.

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.

Commodity clips, 2012 Issue 2
This edition of Commodity clips describes commodity tax developments in the last two months.

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.

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 Management and Accounting Services: Corporate tax rates and legislation—Status for accounting purposes (March 31, 2012)
This quarterly update discusses developments related to the accounting for income taxes, including legislative changes and corporate income tax rates.

Creating a private foundation
A private foundation is a philanthropic vehicle that can provide great flexibility for charitable giving. This article examines the pros and cons of charitable giving through private foundations and how to set them up.

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.