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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 ...
Moodys Gartner Tax Law LLP
Today, the federal government announced Canada's COVID-19 Economic Response Plan (the "Plan"), an $82 billion support plan for individuals and businesses in response to the COVID-19 crisis.
Minden Gross LLP
In the November 2019 TaxLetter issue, I discussed how estate freezes were still a good planning tool for family-owned businesses.
Moodys Gartner Tax Law LLP
On top of these market troubles, our local Alberta economy has suffered a prolonged downturn since 2014.
TaxChambers LLP
Liberal party calls for taxing wealthy may seem non-controversial, but tax lawyers warn of unintended consequences.
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.
O'Sullivan Estate Lawyers LLP
With an aging population, and the trillion dollar transfer of wealth to occur in the face of a shrinking income tax base, and in the face of what some assert is an increasing concentration of wealth at the top, ...
Crowe MacKay LLP
In my view, the most taxpayer-friendly rules in the Canadian tax system include the capital gains exemption on the sale of a Principal Residence...
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.
Siskinds LLP
A Section 85 Tax Rollover ("rollover") is term used to describe a special tax technique that allows a taxpayer to defer all or part of the income which would otherwise be taxed upon transfer.
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.
McLennan Ross LLP
Farming is a fundamental part of our Canadian society and history. Entire generations of families have lived, thrived, and survived on the same land.
O'Sullivan Estate Lawyers LLP
We discussed and compared how our different regimes tax on death, as well as some of the policy issues relating to death taxes.
Minden Gross LLP
Every January, I do the same thing: I vow to try to eat better and to go to the gym. And every February, I'm usually 0 for 2, sadly. But if there's one thing that I do commit to do
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),
O'Sullivan Estate Lawyers LLP
A trust is considered a separate entity and is a taxpayer under the Income Tax Act.
Davies Ward Phillips & Vineberg
With the October federal election looming, 2019 was a relatively quiet year for tax legislation.
O'Sullivan Estate Lawyers LLP
This Advisory provides an overview of some of the key rules regarding the Canadian taxation of estates and testamentary and inter vivos trusts, including spouse, alter ego, joint partner and other life interest trusts ...
Rotfleisch & Samulovitch P.C.
When a taxpayer sells real estate, other than his or her principal residence, any gain realized will be treated as business income or capital gain.
Rotfleisch & Samulovitch P.C.
Generally, when a taxpayer disposes of a capital property—e.g., real property, corporate shares, a partnership interest, mutual funds, etc.—and realizes a capital gain, the taxpayer must include one-half of the gain in his or her income.
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