Tax Notes

April 2013

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Overview of New Canada-Hong Kong Tax Treaty

On November 11, 2012, the Government of Canada signed a tax treaty with the Government of the Hong Kong Special Administrative Region of the People’s Republic of China (referred to herein as “Hong Kong”) for the avoidance of double taxation...

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Canadian Tax Treatment of Mortgage Investment Corporations and Their Shareholders

Greg P. Shannon

A mortgage investment corporation (“MIC”) and its shareholders are entitled to special tax treatment under section 130.1 of the Income Tax Act (Canada) (the “Act”). These special rules were introduced to attract more money to the Canadian mortgage market for...

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Recent Proposed Changes to Rules Applicable to Personal Services Business

Bryant D. Frydberg

Back in the 1970s, while the Montreal Canadiens were dominating the NHL, Ken Dryden backstopped the Canadiens to win six Stanley Cups. While much can be said about Ken Dryden’s heroics in winning the Stanley Cup, this is, after all,...

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Canadian Renewable & Conservation Expense “Green” Energy Tax Incentives

This article is an overview of the Canadian income tax considerations relevant to Canadian renewable and conservation expenses (“CRCE”) initially introduced in the March 1996 Canadian Federal Budget as a new category of deductible expenses and related recent amendments included...

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Overview of Limitation on Benefits Article in Canada-U.S. Tax Treaty

 The Canada-United States Tax Treaty (the “Tax Treaty”) is unique among Canada’s tax treaties in its approach to prevent “treaty shopping”. Treaty shopping generally refers to the acquisition and enjoyment of treaty benefits under a given tax treaty by persons...

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SCC Tax Cases 2012 in Review: The Death of Moldowan and the First Transfer Pricing Decision

David W. Chodikoff

There are only a few tax cases that make it to the Supreme Court of Canada (“SCC”). Indeed, any party that has sought leave to appeal to the SCC knows only too well that it is an exceptionally difficult task....

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Displaying 1-6 of 6