Searching Content indexed under Tax Authorities by Gowling WLG ordered by Published Date Descending.
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Keep Your Eye On The Time: Timing Liability Under Subsection 160(1) In Eyeball Networks
In Eyeball Networks, the TCC alerted tax planners to the pitfalls of issuing and cancelling a promissory note with nominal value in the context of a tax-neutral rollover under section 85 of the ITA
4 Sep 2019
Transfer Pricing: What's New In Canada (Part II)
In Part I of this article,[1] we provided an overview of transfer pricing developments in Canada since the start of the Organization for Economic Cooperation and Development's
4 Sep 2019
Pensions Tax Mistakes Can Sometimes Be Undone
Her Majesty's Revenue and Customs (HMRC) has confirmed it is not appealing against the tribunal's ruling in the case of Hymanson v Revenue and Customs Commissioners [2018] UKFTT 667 (TC)
3 Jul 2019
Packaging Laws In The UK Are Changing - We've Got It Wrapped
The Government has announced four separate consultations all aimed at reducing single-use plastic packaging. We've summarised the key issues that you and your business need to know.
7 May 2019
Permanent Establishment Risks Arising From Globally Mobile Employees
Many businesses with cross border operations rely on their globally mobile employees to maintain relationships with their overseas customer bases.
29 Apr 2019
Québec Moves To Tax Digital Goods And The Virtual Marketplace
Changes to the rules related to the Québec Sales Tax (QST) may mean that your company is now required to collect the QST on sales ...
21 Mar 2019
Accountant Work Product Not Privileged And Must Be Produced To CRA: Canada v. Atlas Tube Canada ULC
In Canada v. Atlas Tube Canada ULC, the Federal Court (FC) ordered a draft due diligence report prepared by Ernst & Young LLP (Canada) to be produced to the Canada Revenue Agency (CRA).
21 Dec 2018
Ain't That A Shame - That Ain't A Sham
Owen J of the Tax Court of Canada ("TCC") visited the sham doctrine twice this Fall, first in Cameco Corporation v. The Queen and then in Lee v. The Queen.
21 Dec 2018
Disruptions Provide Opportunities In The Automotive Industry: How Transfer Pricing Can Help
Record vehicle sales around the world have been motivated, in large part, by expanding global trade agreements that make the buying and selling of automobiles relatively easy.
29 Oct 2018
EPCOR Acquires Collus Powerstream From Town Of Collingwood
On Oct. 3, 2018, the Town of Collingwood announced that it had sold its electrical utility Collus Powerstream to EPCOR Utilities Inc., following the successful completion of two share purchase transactions.
8 Oct 2018
Federal Court Restricts Canada Revenue Agency Fishing Expeditions For "Unnamed Persons"
In Canada (National Revenue) v. Hydro-Québec (2018 FC 62), the Federal Court restricted the Canada Revenue Agency's authority to force businesses to provide information about their customers pursuant to section 231.2 of the Income Tax Act.
23 Sep 2018
No Rubbing Salt In The Wound: The Canada Revenue Agency Provides Tax Relief For Losses From Fraudulent Investment Schemes
Taxpayers victimized by fraudulent investment schemes ("Fraudulent Investment Schemes") may find some relief by deducting their losses. Recent Canada Revenue Agency ("CRA") administrative statements...
19 Sep 2018
Anticipating The Tax Implications Of Brexit
While it is still too early to take a position on the actual consequences of the Brexit, the main tax implications for groups with operations both in France and in the UK can and should already be anticipated.
European Union
10 Sep 2018
Canada Revenue Agency's Dogged Pursuit Of Offshore Accounts: Clarifying The Scope Of Compliance Orders In Canada v Stankovic
The Federal Court's ("FC") ruling in Canada v Stankovic, 2018 FC 462 illustrates how the Canada Revenue Agency ("CRA") persistently pursues taxpayers with undisclosed offshore accounts.
16 May 2018
Budget 2018: Sensible Measures
From a tax perspective, the headline news is that Budget 2018 completes the Government of Canada's general retreat from the astounding July Proposals to address passive investment income in private corporations.
28 Feb 2018
New Voluntary Disclosures Program: Coming Soon!
Presumably experienced professional advisors will not require that kind of discussion.
21 Feb 2018
Clarifying The Uses Of Amended Returns In Vine Estate v. Canada
The Federal Court of Appeal's ruling in Vine Estate v. Canada reminds taxpayers of the importance of filing their original tax return correctly and applying the appropriate degree of care in the process.
20 Feb 2018
How Many More Times Will The CRA Get Re-Appropriation Wrong?
In Referred Realty Inc. (2018 FC 59), the Canada Revenue Agency's ("CRA") misguided approach to T2 re-appropriation was rejected by the Federal Court — for the third time in recent memory.
20 Feb 2018
Bloomberg Tax Transfer Pricing Forum
If a senior manager or management team is relocated into or out of your jurisdiction, does your country have a view about whether the transfer is purely a services transfer, or includes an intangible asset such as goodwill ...
17 Jan 2018
CRA Finalizes New Information Circular For Income Tax Voluntary Disclosures Program
On December 15, 2017, the CRA released the final version of Information Circular IC 00-1R6 – Voluntary Disclosures Program ("VDP") for income tax, after receiving and considering community input ...
20 Dec 2017
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