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On February 12, 2020, in Canada v Alta Energy Luxembourg S.A.R.L. (2020 FCA 43), the Federal Court of Appeal ("FCA") unanimously held that the general anti-avoidance rule ...
Miller Thomson LLP
Subsection 107(2) of the Income Tax Act[1] generally provides for a tax-deferred rollout of capital property held by the trustees of a Canadian-resident personal trust to their capital beneficiaries in satisfaction of their capital interests in the trust.
Rotfleisch & Samulovitch P.C.
Section 261 of Income Tax Act generally requires amounts reported on Canadian tax returns and other tax filings be reported in Canadian currency.
Bennett Jones LLP
The FCA found that the object, spirit and purpose of the relevant Can-Lux Treaty provisions is reflected in the clear and simple text of the Treaty.
McCarthy Tétrault LLP
In Her Majesty the Queen v. Alta Energy Luxembourg S.A.R.L., the Federal Court of Appeal confirmed that so-called "treaty shopping" is not abusive of Canada's tax treaties.
Osler, Hoskin & Harcourt LLP
In Canada v Alta Energy Luxembourg S.A.R.L., the Federal Court of Appeal (FCA) confirmed there was no abusive tax avoidance under Canada's general anti-avoidance rule (GAAR) ...
Aird & Berlis LLP
The Federal Court of Appeal in Alta Energy1 held that the Appellant, a Luxembourg corporation, could properly rely on the Canada-Luxembourg Treaty.
Torys LLP
On February 12, the Federal Court of Appeal (FCA) released its decision in The Queen v. Alta Energy Luxembourg S.a.r.l.1 (Alta Energy),
Osler, Hoskin & Harcourt LLP
The OECD has been working on a two-pillar approach to international tax reform: (a) Pillar One...
Miller Thomson LLP
Domicile is generally not relevant to the determination of an individual's Canadian tax liability. Rather, the rationale for imposing Canadian income taxes on individuals is based on the concept of tax residence in Canada ...
TaxChambers LLP
As we commence the new year (2020), we prepare ourselves for what awaits us: spring showers, flowers, and the hand of the tax collector reaching into our pockets.
Davies Ward Phillips & Vineberg
In a case argued by Davies, the Court of Québec rendered a judgment on December 10 setting out, for the first time, the conditions that must be met for the electronic disclosure of evidence by the Crown to be "reasonably accessible", ...
McLennan Ross LLP
Typically, foreign nationals require Work Permits before they can conduct any work in Canada. However, where a foreign national is entering Canada to perform international business activities...
Osler, Hoskin & Harcourt LLP
Earlier in 2019, the OECD published its Programme of Work to Develop a Consensus Solution to the Tax Challenges Arising from the Digitalization of the Economy (Program of Work), ...
Rotfleisch & Samulovitch P.C.
Taxation has become an increasingly global issue as people, money and property move freely across borders.
Osler, Hoskin & Harcourt LLP
Earlier in 2019, the OECD published its Programme of Work [PDF] to Develop a Consensus Solution to the Tax Challenges Arising from the Digitalization of the Economy (Program of Work)
Minden Gross LLP
This paper will discuss a limited selection of Canadian income tax issues arising in estate administration1 as follows.
Blaney McMurtry LLP
2019 by the American Bar Association. Reprinted with permission. All rights reserved. This information or any or portion thereof may not be copied or disseminated in any form ...
Rotfleisch & Samulovitch P.C.
To many people, an unlimited liability company (ULC) may sound like a contradiction in terms.
Blaney McMurtry LLP
When asking a U.S. tax adviser to describe the "revenue rule," it would not be surprising for the adviser to say that it refers to formal guidance issued by the I.R.S. that can be relied on by...
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