Regan A. O'Neil

Partner | Calgary


Portrait of Regan A.  O’Neil

Release of draft Canadian tax legislation

On August 9, 2022, legislative proposals relating to the Income Tax Act (the “Act”) and other tax legislation were released by the Department of Finance for public feedback (the “August Proposals”). The August Proposals seek to implement certain measures previously...


Failed claim of solicitor-client privilege: Commentary on Minister of National Revenue v. BMO Nesbitt Burns Inc., 2022 FC 157

In the 2022 case, Minister of National Revenue v. BMO Nesbitt Burns Inc., the Minister of National Revenue (the “Minister”) made an application pursuant to section 231.7 of the Income Tax Act (Canada) (the “Act”) for an order requiring BMO...


Release of draft Canadian tax legislation for public consultation

An extensive package of draft legislative proposals was released for public comment by the Department of Finance on February 4, 2022 (the “Proposals”) along with explanatory notes (the “Notes”).  The Proposals include some, but not all, of the measures announced...


Have losses? Plan so that you can use them!

One of the consequences of COVID-19 is volatility in the stock market.  Some investors facing losses in their portfolios are considering strategies to crystallize them and use the losses to offset capital gains.  One-half of capital losses (referred to as...


Planning To Sell Goodwill – Tax Implications of the 2016 Federal Budget

Eligible capital property (“ECP”) includes such things as customer lists, franchise rights, licenses, quotas and other intangibles.  ECP also includes goodwill, which in general terms is the value of a company beyond the value of its tangible and other specified...


( Available in French only )

Planification de vente d’achalandage – Incidences fiscales du budget fédéral de 2016

Les immobilisations admissibles comprennent les listes de clients, les droits de franchise, les permis, les licences, les quotas et d’autres biens incorporels. Elles comprennent également l’achalandage, qui correspond de façon générale à l’excédent de la valeur d’une société sur la...


Tax on Corporate Transactions in Canada

Practical Law (a Thomson Reuters publication)

Chapter in Tax on Transactions Multi-jurisdictional Guide.


Income Splitting via Loans – Prescribed Interest Rate to Increase Soon

Prescribed rate loans can be used to shift income from a spouse or parent in a high income tax bracket to a spouse or child in a lower income tax bracket; if carried out properly, the attribution rules in the...


2013 Provincial Budget Highlights

AlbertaBritish ColumbiaOntarioQuébec (English Version)Québec (Version Française)Saskatchewan 2013 Alberta Budget Highlights Regan A. O’Neil, Calgary The 2013 Alberta Budget tabled by The Honourable Doug Horner, Minister of Finance, on March 7, 2013 received royal assent on April 29, 2013.  Corporate and...


Beneficial Ownership Test For Tax Treaty Benefit Entitlement

In Velcro Canada Inc. v. Her Majesty the Queen  (2012 TCC 57), the Tax Court of Canada (the “TCC”) applied the test of beneficial ownership as established by the Federal Court of Appeal in Prévost Car Inc. v. Canada (2009...


Federal Budget Review

View the Federal Budget Review