John M. Campbell

Partner | Toronto

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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...

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Case Review: The TDL Group Co. v. The Queen

Taxes & Wealth Management, Thomson Reuters, Issue 8-2, May 2015, 10-14

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Canada’s Focus on International Tax

IFA Korea Journal

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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...

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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...

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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...

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International Tax Update

International Tax Newsletter

View the November 2012 issue.

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Federal Budget Review

View the Federal Budget Review

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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...

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Foreign Exchange Gains and Losses

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Ontario Capital Tax – Is Inventory Financing Exempt?

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New Draft Income Tax Legislation Respecting Non-Competition Covenants and Other Restrictive Covenants

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Non-Resident Trust and Foreign Investment Entity Changes Postponed

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Cross Border Intercompany Management and Administration Charges

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Withholding Tax Exemption for Computer Software Royalties Broadened

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Tax Treaty Status Report

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Non-Resident Trusts – New Draft Legislation

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Tax Planning for the Private Company Shareholder on Death

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Thin Capitalization Rules Tightened

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Personal Tax Rates

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