Canada Emergency Wage Subsidy: As enacted, extended and proposed to be amended
Updated on May 19, 2020 To encourage businesses to retain their employees during the COVID-19 pandemic, Parliament convened on an emergency basis on April 11, 2020 to enact Bill C-14, which legislates the Canada Emergency Wage Subsidy (the “CEWS”). Details...
Case Review: The TDL Group Co. v. The Queen
Taxes & Wealth Management, Thomson Reuters, Issue 8-2, May 2015, 10-14
Canada’s Focus on International Tax
IFA Korea Journal
Foreign Affiliate Dumping Transactions
Anti-Surplus Stripping Rule for Canadian Resident Corporations Controlled by Non-Residents Bill C-45 adds a new anti-surplus stripping rule to the Income Tax Act (Canada) (the “Act”) as section 212.3. This provision will apply to a corporation that is: resident in...
Pertinent Loan or Indebtedness Regime
IN THIS SECTION: PLOI Relieving Rule for Subsection 15(2) Shareholder Indebtedness Scope of PLOI Exception PLOI Elections Certain Reorganizations Involving Canadian Resident Corporate Creditors Deemed Interest Income To File or Not to File a PLOI Election? Application Date PLOI Relieving...
Thin Capitalization Regime
Existing Canadian Thin Cap Regime The existing Canadian thin cap regime protects the Canadian tax base from excessive interest deductions by limiting the amount of interest expense that can be deducted by a corporation resident in Canada16 (“Canco”) on cross-border...
International Tax Update
International Tax Newsletter
View the November 2012 issue.
Federal Budget Review
View the Federal Budget Review
Upstream Loans and Other Indebtedness to Foreign Affiliates
Draft legislation making significant changes to the foreign affiliate provisions of the Income Tax Act (Canada) (the “Act”) was released by the Department of Finance on August 19, 2011. The new provisions deal with upstream loans from and other indebtedness...
Foreign Exchange Gains and Losses
Ontario Capital Tax – Is Inventory Financing Exempt?
New Draft Income Tax Legislation Respecting Non-Competition Covenants and Other Restrictive Covenants
Non-Resident Trust and Foreign Investment Entity Changes Postponed
Cross Border Intercompany Management and Administration Charges
Withholding Tax Exemption for Computer Software Royalties Broadened
Tax Treaty Status Report
Non-Resident Trusts – New Draft Legislation
Tax Planning for the Private Company Shareholder on Death
Thin Capitalization Rules Tightened
Personal Tax Rates