The Department of Finance recently released a package of materials containing potential changes to the Canadian tax system (Tax Proposals). The materials, released on August 9, 2022, include draft amendments to the Income Tax...more
8/24/2022
/ Canada ,
Department of Finance ,
Disclosure Requirements ,
Financial Institutions ,
Foreign Subsidiaries ,
GAAR ,
Income Tax Act ,
Internal Revenue Code (IRC) ,
Net Investment Income ,
OECD ,
Partnerships ,
Privately Held Corporations ,
Shareholders ,
Withholding Tax
“Equity has no place here,” held the Supreme Court of Canada in its 8-1 decision in Canada (Attorney General) v Collins Family Trust (Collins), 2022 SCC 26, on June 17. Reversing the decisions of the British Columbia courts...more
6/22/2022
/ Business Assets ,
Canada Revenue Agency (CRA) ,
Creditors ,
Dividends ,
Equity ,
Fair Market Value ,
Family Trusts ,
Holding Companies ,
Income Tax Act ,
Rescission ,
Supreme Court of Canada ,
Tax Liability ,
Tax Planning
In The Bank of Nova Scotia v The Queen, the Tax Court of Canada (TCC) considered how to calculate arrears interest on an audit adjustment that is offset by a loss carryback. ...more
11/5/2021
/ Arrearages ,
Back Taxes ,
Canada ,
Carryback Rules ,
Delinquency Status ,
Income Tax Act ,
Income Taxes ,
Interest Accrual ,
Reassessments ,
Tax Court ,
Tax Debt ,
Tax Liability ,
Tax Planning ,
Transfer Pricing