Tax Notes
December 2011
Upstream Loans and Other Indebtedness to Foreign Affiliates
CRA Guidance on Whether Canadian Captive Service Subsidiary Constitutes PE of Foreign Parent
Court Upholds Capital Loss Recognition on Exercise of Exchangeable Share Rights
Employee Profit Sharing Plans - Changes to Come?
Change to Canada-US Tax Treaty Affecting Cross-Border Employees
Back to the Future – British Columbia Votes to Restore Provincial Sales Tax
CRA Guidance on Whether Canadian Captive Service Subsidiary Constitutes PE of Foreign Parent
Court Upholds Capital Loss Recognition on Exercise of Exchangeable Share Rights
Employee Profit Sharing Plans - Changes to Come?
Change to Canada-US Tax Treaty Affecting Cross-Border Employees
Back to the Future – British Columbia Votes to Restore Provincial Sales Tax
June 2011
Miller Thomson's National M&A Work is Ranked Top Tier Among Canadian Law Firms and Globally
Cross-Border and International Tax: New Canadian Compliance Requirements for Non-Residents of Canada
2011 Federal Budget - Focus on Anti-Avoidance Rules
Legislative Responses to Recent Canadian Tax Cases: Deductibility of Contingent Expenditures, Non-Resident Withholding Tax on Interest, and Segregated Fund Policy Reserves
Tax Tip - Share Consideration Issued on a Tax-Deferred Rollover
Cross-Border and International Tax: New Canadian Compliance Requirements for Non-Residents of Canada
2011 Federal Budget - Focus on Anti-Avoidance Rules
Legislative Responses to Recent Canadian Tax Cases: Deductibility of Contingent Expenditures, Non-Resident Withholding Tax on Interest, and Segregated Fund Policy Reserves
Tax Tip - Share Consideration Issued on a Tax-Deferred Rollover
October 5, 2010
Current Cases: Sale Of Business - Defining Goodwill And Defending The Purchase Price Allocation
Cross-Border Tax: Canada-US Tax Treaty Update - CRA Views On Treaty Entitlement On Canadian Source Income And Profit For US LLC Shareholders
Canadian Tax: Update On Restrictive Covenant Proposals
International Tax: The Lehigh Cement Case - Canadian Non-Resident Withholding Tax On Interest Payments
International Tax: Tax Information Exchange Agreements - Overview And Update
New Charity Tax Specific Graduate Degree
Cross-Border Tax: Canada-US Tax Treaty Update - CRA Views On Treaty Entitlement On Canadian Source Income And Profit For US LLC Shareholders
Canadian Tax: Update On Restrictive Covenant Proposals
International Tax: The Lehigh Cement Case - Canadian Non-Resident Withholding Tax On Interest Payments
International Tax: Tax Information Exchange Agreements - Overview And Update
New Charity Tax Specific Graduate Degree
July 2010
The Miller Thomson Foundation: Sixteen Years as a Proud Supporter of Post-Secondary Education in Canada
Cross-Border Tax: Canada-US Tax Treaty Update: CRA Views on Treaty Benefits on Dividends Paid by Canadian ULC's
International Tax: Recent Changes to "taxable Canadian property" Regime for Purchasers and Non-resident Vendors of TCP
Harmonized Sales Tax (HST): The New HST and the Place of Supply Rules
Canadian Tax: Recent Changes to the Employee Stock Options Rules
Current Cases: The Propep Decision: The Associated Corporation Rules
Provincial Tax: Introduction of HST - B.C. Transitional Rules
2010-2011 Quebec Budget Highlights
2010-2011 Ontario Budget Highlights
2010-2011 British Columbia Budget Highlights
2010-2011 Alberta Budget Highlights
Cross-Border Tax: Canada-US Tax Treaty Update: CRA Views on Treaty Benefits on Dividends Paid by Canadian ULC's
International Tax: Recent Changes to "taxable Canadian property" Regime for Purchasers and Non-resident Vendors of TCP
Harmonized Sales Tax (HST): The New HST and the Place of Supply Rules
Canadian Tax: Recent Changes to the Employee Stock Options Rules
Current Cases: The Propep Decision: The Associated Corporation Rules
Provincial Tax: Introduction of HST - B.C. Transitional Rules
2010-2011 Quebec Budget Highlights
2010-2011 Ontario Budget Highlights
2010-2011 British Columbia Budget Highlights
2010-2011 Alberta Budget Highlights
March 2010
Cross-Border Tax: Canada-US Tax Treaty Update: Canada Revenue Agency Views on Solutions for Interest and Other Payments from Canadian Unlimited Liability Companies
Cross-Border Tax: Canadian Multinationals Allowed to Double-Dip
Current Cases: General Electric Case: Deductibility of Guarantee Fees
International Tax: More Guidance Required from Canada Revenue Agency on So-called "Non-Traditional Convertible Debt Obligations"
International Tax: Corporate Residency - A New Approach to the Application of Central Management and Control
Provincial Tax: Québec Intensifies its Fight Against Aggressive Tax Planning Schemes
Cross-Border Tax: Canadian Multinationals Allowed to Double-Dip
Current Cases: General Electric Case: Deductibility of Guarantee Fees
International Tax: More Guidance Required from Canada Revenue Agency on So-called "Non-Traditional Convertible Debt Obligations"
International Tax: Corporate Residency - A New Approach to the Application of Central Management and Control
Provincial Tax: Québec Intensifies its Fight Against Aggressive Tax Planning Schemes
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