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Canada Tax Planning

Blake, Cassels & Graydon LLP

Budget 2025-2026 du Québec : Points saillants en matière de fiscalité

Le 25 mars 2025, le ministre des Finances du Québec, Eric Girard, a déposé le budget 2025-2026 du Québec (le « budget 2025-2026 »). Intitulé Pour un Québec fort, ce budget est axé sur des investissements ayant pour but...more

Bennett Jones LLP

Turning Losses Into Gains: Private Equity Tax Strategies With Distressed Businesses

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Private equity (PE) firms play a critical role in revitalizing struggling businesses by providing, among other things, financial support and operational expertise. PE transactions are often driven by a combination of...more

Pierce Atwood LLP

Transfer Pricing and Tariffs: Finding Certainty in Trade Uncertainty

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The current administration’s whipsaw of imposed and withdrawn tariffs continues to rattle financial markets and industries across the United States. In New England, annual trade of goods and services with Canada exceeds...more

Proskauer Rose LLP

UK Tax Round Up - February 2025

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Welcome to February’s edition of the UK Tax Round Up. This month has seen a number of interesting decisions covering the unallowable purpose test in relation to cross border group relief tax losses, the application of the...more

Bennett Jones LLP

High-Net-Worth Investors to Boost Growth in Private Equity: Opportunities, Risks and Other Important Considerations

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Globally, private equity is expected to double its current assets under management (AUM) to US$12 trillion by the end of 2029, driven in large part by private wealth investors, according to new Preqin research....more

Bennett Jones LLP

Bennett Jones Leading the Way in Employee Ownership Trusts

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Effective January 1, 2024, Canada introduced detailed rules into the Income Tax Act (Canada) to facilitate and encourage employee ownership of small and medium sized Canadian businesses through the creation of employee...more

Procopio, Cory, Hargreaves & Savitch LLP

Understanding Tariffs and Strategies for Mitigating Their Impact

In recent months, tariffs have become a significant concern for businesses importing goods, particularly in relation to trade agreements between the U.S., Mexico, and Canada, as well as with other countries. The U.S....more

Stikeman Elliott LLP

Tax Court of Canada Denies GST/HST Input Tax Credit Claims in Connection with a Settlement Payment

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In a general procedure hearing that was later moved under the informal procedure rules and rendered on December 17, 2024, the Tax Court of Canada (the “Tax Court”) dismissed 267 O’Connor Limited’s (the “Appellant”) appeal,...more

Blake, Cassels & Graydon LLP

Pensions and Employee Benefits: Trends for 2025

Looking ahead to 2025 in the area of pensions and employee benefits, several notable trends stand out. The following is a summary of the key trends for 2025...more

Davies Ward Phillips & Vineberg LLP

Selected US Tax Developments

Canadians who emigrate to the United States or elsewhere face many decisions and considerations associated with departure, but careful tax planning should not be an afterthought. When an individual ceases to be resident in...more

Blake, Cassels & Graydon LLP

Tax Update: Proposed Increase to Capital Gains Inclusion Rate Deferred to 2026

On January 31, 2025, the Minister of Finance (Canada) announced that the proposed increase in the capital gains inclusion rate from one-half to two-thirds, previously intended to be effective for dispositions occurring on or...more

Dorsey & Whitney LLP

Certain Canadian Corporations May Unknowingly be Subject to U.S. Federal Backup Withholding and Reporting Requirements With...

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Canadian corporations making dividend payments should ensure that they are compliant with U.S. federal backup withholding and reporting requirements to avoid potential U.S. federal income tax issues....more

Morgan Lewis

Key Takeaways: US-Canada Transfer Pricing & Tax Controversies: What’s New, What’s Not, and How to Prepare for Both

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The global tax enforcement landscape is progressing rapidly, driven by regulatory changes, increasing cross-border collaboration, and shifts in funding for key tax authorities. Businesses operating in multiple jurisdictions...more

Stikeman Elliott LLP

Prorogation of Parliament and the Proposed Capital Gains Inclusion Rate Increase

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On January 6, 2025, Prime Minister Justin Trudeau announced his resignation as prime minister and the prorogation of Parliament until March 24, 2025. At the federal level, prorogation is an act by the Governor General,...more

Bennett Jones LLP

2024 Taxation Year Reporting Exemption for Bare Trusts

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On October 29, 2024, the Canada Revenue Agency (CRA) announced that bare trusts are once again exempt from filing the T3 Income Tax and Information Return (including Schedule 15 regarding beneficial ownership information of a...more

Stikeman Elliott LLP

Understanding Canada’s New Digital Services Tax

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Canada’s Digital Services Tax Act was enacted on June 20, 2024 and came into effect by Order in Council on June 28, 2024. The new legislation imposes a digital services tax of 3% on digital services revenue exceeding...more

Blake, Cassels & Graydon LLP

Vente d’une entreprise de distribution d’assurances : mettre toutes les chances de son côté

Le marché fragmenté de la distribution d’assurances au Canada continue de faire l’objet d’un grand volume d’activités de fusion et acquisition (« F&A ») alors que les consolidateurs établis regroupent de petits courtiers...more

Blake, Cassels & Graydon LLP

Getting the Deal Done: Insurance Distribution

The fragmented insurance distribution market in Canada continues to see significant levels of mergers and acquisitions (M&A) activity as established consolidators roll up smaller brokerages and managing general agents (MGAs),...more

Bennett Jones LLP

Tenants Beware: The Risks of Landlord Tax Liabilities

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A recent ruling from the Tax Court of Canada underscores the significance of tenants verifying their landlords' residency status in adhering to any obligations to withhold taxes in accordance with Part XIII of the Income Tax...more

Bennett Jones LLP

Incentivizing Employees: Avoiding a Salary Deferral Arrangement

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Incentivizing employees is a critical component of most business strategies. Employers may implement arrangements for deferred cash bonuses, often subject to the satisfaction of certain criteria. From a tax perspective, the...more

Blake, Cassels & Graydon LLP

Le point sur les déclarations obligatoires : le ministère des Finances introduit des règles mises à jour

Le 17 avril 2023, le ministère des Finances du Canada (le « Ministère ») a publié un avis de motion de voies et moyens (l’« Avis ») relatif à la mise en œuvre de certaines propositions prévues au budget fédéral de 2023....more

Blake, Cassels & Graydon LLP

Mandatory Disclosure Update: Department of Finance Introduces Revised Rules in the House of Commons

On April 17, 2023, the Department of Finance (Finance) released a Notice of Ways and Means Motion (NWMM) to implement certain proposals announced in the 2023 Federal Budget. The NWMM also includes much-awaited updated...more

Bennett Jones LLP

Canadian Investment Tax Credits for Clean Technologies and Clean Hydrogen Announced in 2022 Fall Economic

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Key Highlights - - Proposed 30 percent refundable Clean Technology Investment Tax Credit. - Proposed refundable Clean Hydrogen Investment Tax Credit. - Further details and consultations are forthcoming. -...more

Bennett Jones LLP

Canada Proposes New Tax On Share Buybacks

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The federal government's 2022 Fall Economic Statement (Economic Statement), released on November 3, 2022, introduced a new tax on share buybacks by public corporations in Canada. Under the proposal, which would come into...more

Stikeman Elliott LLP

GST/HST Input Tax Credit Claims: Does the Supporting Documentation Need to be Issued by the Supplier?

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On June 9, 2022, the Tax Court of Canada (“TCC”) allowed CFI Funding Trust’s (“CFI”) appeal in relation with the input tax credits (“ITC”) it claimed for prepaid rent paid in connection with the securitization of automobile...more

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