Corporate Tax

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New Proposed Limits on Employee Stock Option Deductions

Introduction The long-standing tradition of using employee stock options to reward and retain employees in Canada may change due to limits proposed by the federal government to the current advantageous tax treatment available to employees in certain circumstances. Currently, subsection...

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Interjurisdictional Road Carriers – Registration Under the Greenhouse Gas Pollution Pricing Act

On April 1, 2019, the Greenhouse Gas Pollution Pricing Act (the “Act”) came into force in Manitoba, New Brunswick, Ontario and Saskatchewan, and it will come into force on July 1, 2019 for each of Nunavut and the Yukon (the...

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2019 Miller Thomson Federal Budget Review

Disponible en français :  Analyse du budget fédéral de 2019 par Miller Thomson With the tabling of its federal Budget (“Budget 2019”), the Federal Government (the “Government”) has renewed its commitment to “investing” in the Canadian middle class (and in...

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Callidus Capital Corporation v Her Majesty the Queen SCC Appeal Granted

In a rare move, the Supreme Court of Canada has allowed the Callidus Capital Corporation appeal from the bench. This appeal involved the priority between secured creditors and the Canada Revenue Agency under the Excise Tax Act once a tax...

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John Grant quoted in The Globe and Mail’s article on “Taxed: The CRA’s battle with small business”

The Globe and Mail, "Taxed: The CRA's battle with small business"

Quebec Superior Court found the CRA negligent in conducting an offshore tax audit. John Grant speaks on possible effects. [Article only available to The Globe and Mail subscribers] For more, click here.

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Highlights of the USMCA

On September 30, 2018, the United States, Mexico and Canada reached a new trade agreement, the United States–Mexico-Canada Agreement (“USMCA”). This agreement maintains a free-trade zone between the three countries and could be signed prior to December 1, 2018. The...

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Excise Tax Act Amendments Released July 2018

On July 27, 2018, the Department of Finance (“Finance”) released the Legislative and Regulatory Proposals Relating to the Excise Tax Act (Canada) (the “ETA”), including amendments to sections 186 and 289.2 and subsection 292(7) (the “Proposals”). Section 186 – Holding...

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Ron Choudhury and Andrew Etcovitch quoted in Bloomberg article on input tax credit limits for holding companies

Bloomberg, "Canada Plans to Limit Input Tax Credits for Holding Companies"

The Canadian government has proposed limiting the amount holding companies can recover from value-added and sales tax they pay on goods and services purchased for an operating subsidiary. […] This will have limited application to foreign multinationals, as it only applies...

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A New Era of Private Corporation Tax Rules – Part IV

On June 21, 2018 Bill C-74, An Act to implement certain provisions of the budget tabled in Parliament on February 27, 2018 and other measures (“Bill C-74”) received Royal Assent. Bill C‑74 includes various amendments to the Income Tax Act...

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Canada-U.S. Trade War? Canada Retaliates with New Tariffs on U.S. Goods

On June 29, 2018, the Canadian Government announced that it would implement countermeasures in response to what it called “unjustified tariffs on Canadian steel and aluminum products.” These countermeasures are in direct response to the United States imposing tariffs on...

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Leading tax lawyer

Proud to announce Partner Cathie Brayley has been recognized as a ‘highly regarded’ tax lawyer by International Tax Review’s Women in Tax Leaders: Guide to the World’s Leading Female Tax Practitioners.

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Federal Budget Review

Read our Federal Budget Review for insights and analysis into key areas of the budget and how developments might affect you and your business.

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Tax Notes

Read the latest issue of Miller Thomson’s Tax Notes publication

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