The Canadian Department of Finance introduced draft legislation in the 2023 Canadian Federal Budget (Budget 2023) to create employee ownership trusts (EOTs) to facilitate the transfer of a business to the employees of the...more
With the enactment of Bill C-47 on June 22, 2023, Canada's enhanced mandatory disclosure rules are now fully in effect. These rules, which were first announced in the 2021 Canadian federal budget...more
On February 12, 2020, the Federal Court of Appeal (FCA) in Canada v Alta Energy Luxembourg S.A.R.L., 2020 FCA 43 [Alta Lux] concluded that the Canada-Luxembourg tax treaty (Can-Lux Treaty) was not abused when a Luxembourg...more
2/27/2020
/ Anti-Avoidance ,
Capital Gains ,
Corporate Taxes ,
GAAR ,
Income Taxes ,
International Tax Issues ,
OECD ,
Principal Purpose Test ,
Private Equity Firms ,
Tax Treaty ,
Withholding Tax
Roughly one year after U.S. tax reform, the Department of Finance has introduced amendments to Canada's income tax laws aimed at encouraging investment in Canada. The proposed changes included in the Fall Economic Statement...more
12/5/2018
/ Canada ,
Charitable Donations ,
Corporate Taxes ,
Foreign Investment ,
Incentives ,
Income Taxes ,
Investment Tax Credits ,
Mineral Exploration ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Incentives
The Tax Court of Canada recently held, in Alta Energy Luxembourg SARL v R, 2018 TCC 152, that a Luxembourg S.A.R.L was entitled to treaty benefits on capital gains and that the general anti-avoidance rule ("GAAR") did not...more