News & Analysis as of

Tax Reform Tax Planning Canada

Cozen O'Connor

What Canadian High Net Worth Families Should Know About the U.S. One Big Beautiful Bill

Cozen O'Connor on

The United States recently passed tax legislation called the One Big Beautiful Bill Act (OBBBA), a follow-up to the 2017 Trump tax cuts. While the bill is American, many Canadian families with cross-border ties, including...more

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

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

Morgan Lewis

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

Morgan Lewis on

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

Stikeman Elliott LLP on

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

Bennett Jones LLP on

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

Bennett Jones LLP

Incentivizing Employees: Avoiding a Salary Deferral Arrangement

Bennett Jones LLP on

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

Bennett Jones LLP

Canada Proposes New Tax On Share Buybacks

Bennett Jones LLP on

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?

Stikeman Elliott LLP on

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

Bennett Jones LLP

Income Tax Update from the Supreme Court of Canada: The GAAR Does Not Apply to Treaty Shopping

Bennett Jones LLP on

The Duke of Westminster Principle Still Lives On for Tax Planning - On November 26, 2021, the Supreme Court of Canada released its decision and reasons in Her Majesty the Queen and Alta Energy Luxembourg S.A.R.L., 2021 SCC...more

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