Mondaq Canada: Tax
Rotfleisch & Samulovitch P.C.
During a typical tax dispute between a taxpayer and the CRA, the CRA will advance one or several grounds for the assessment or reassessment against a taxpayer.
Rotfleisch & Samulovitch P.C.
Emigrating from Canada has a multitude of tax implications including which country can tax particular income and the Canadian tax owed for emigrating.
Rotfleisch & Samulovitch P.C.
Under the Income Tax Act, RSC 1985, c 1 (5th Supp) ("ITA") 164(3) the CRA must refund interest at a prescribed rate based on the amount in respect of a taxation year that is refunded or repaid.
Rotfleisch & Samulovitch P.C.
MNR v Cameco Corporation (2019 FCA 67) shows that the Canada Revenue Agency's tax-audit powers—while broad—come with limits.
Bennett Jones LLP
The latest edition of Bennett Jones on Tax Disputes, published on Taxnet Pro by Thomson Reuters,...
McMillan LLP
On May 31, 2019, as one of the main areas of focus of the ongoing work on the Base Erosion and Profit Shifting ("BEPS") project, Members of the OECD/G20 Inclusive Framework on BEPS ("Framework")
Minden Gross LLP
The implementation of various amendments to the Income Tax Act (Canada) on December 14, 2017, saw a marked tightening of the mechanisms that allow a taxpayer to qualify for, and make use of, the principal residence exemption.
Borden Ladner Gervais LLP
As part of its initiative to protect the integrity and fairness of its tax system, the provincial 2019-2020 budget put an emphasis on the disclosure requirement of nominee agreements.
Miller Thomson LLP
On March 19, 2019, the Federal Budget proposed to change the employee stock option tax regime.
Crowe Soberman LLP
Canadian GST/HST is not supposed to be a business cost to foreign airlines that are simply landing or departing from Canada as part of an international flight.
Spiegel Sohmer
On May 17, 2019, Finance Quebec released measures to deal with combating aggressive tax planning.
Rotfleisch & Samulovitch P.C.
When a taxpayer carries on a commercial activity it inevitably incurs the additional expense of GST/HST payable on its supplies.
LexSage
This would allow the CRA auditor to see what changed from the draft report to the final report.
Davies Ward Phillips & Vineberg
Canada is expected to notify the OECD within the next few months that it has ratified the MLI.
Gowling WLG
As Celine Dion once sang, taxes are as inevitable as rain.
Rotfleisch & Samulovitch P.C.
The plaintiffs, Allan Jay Gordon, James A. Deacur and Associates Ltd. [and James Allan Deacur sought damages from the government of Canada alleging that the Canada Revenue Agency conducted tortious act in its criminal investigation.
Rotfleisch & Samulovitch P.C.
Taxation of inter-corporate dividends has been expanded by amendments to Subsection 55(2) of the Income Tax Act first proposed in the 2015 Federal Budget.
Davies Ward Phillips & Vineberg
The federal government has released much anticipated draft legislation proposing changes to the rules relating to the taxation of stock options.
Davies Ward Phillips & Vineberg
Québec's Ministry of Finance (Finances Québec) recently published Information Bulletin 2019-5 (Bulletin) setting out new and significantly expanded measures to combat aggressive tax planning.
Fasken
In February and March of 2019, the OECD organized a public consultation process, releasing a consultation document on February 13, 2019, inviting public comments up until March 6, 2019, and holding a conference where industry...
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Alexander Holburn Beaudin + Lang LLP
For a few months during the summer of 2018, Fortis BC closed a long strip of Vancouver's East 1st Avenue to conduct gas line work.
Clark Wilson LLP
The case of Gully v Gully, 2018 BCSC 1590 provides useful insight on a peril of putting property into joint tenancy. The decision illustrates the importance of considering the financial status...
Rotfleisch & Samulovitch P.C.
These deemed-dividend rules are found in section 84 of Canada's Income Tax Act.
Goodmans LLP
Successful cleantech ventures often bring together different industry and professional sectors.
Siskinds LLP
On May 22, 2019 the Alberta government tabled the Carbon Tax Repeal Act to immediately repeal the existing carbon levy. The repeal of the Carbon Tax Repeal Act is under the provisions of Bill 1
Rotfleisch & Samulovitch P.C.
This article looks at the tax dispute between the Canada Revenue Agency and Uber Canada Inc. Afterwards, we provide GST/HST tax tips based on the lessons we might draw from the outcome of this dispute.
Rotfleisch & Samulovitch P.C.
When a taxpayer carries on a commercial activity it inevitably incurs the additional expense of GST/HST payable on its supplies.
Rotfleisch & Samulovitch P.C.
In Canada (National Revenue) v Atlas Tube Canada ULC, the Federal Court held that Canada Revenue Agency could compel a private corporation to disclose its draft tax due diligence report during the course of an ongoing audit.
Davies Ward Phillips & Vineberg
Québec's Ministry of Finance (Finances Québec) recently published Information Bulletin 2019-5 (Bulletin) setting out new and significantly expanded measures to combat aggressive tax planning.
Rotfleisch & Samulovitch P.C.
The plaintiffs, Allan Jay Gordon, James A. Deacur and Associates Ltd. [and James Allan Deacur sought damages from the government of Canada alleging that the Canada Revenue Agency conducted tortious act in its criminal investigation.
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