Tax Notes

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August 17, 2022

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Is the interest deductible? – Fundamentals of interest deductibility in Canada

Pierce Quaghebeur

The rules around interest deductibility are becoming more and more complex. As a business grows and expands their operations to new jurisdictions, and adopts a corporate structure designed to take advantage of certain opportunities related to interest deductibility, the business...

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

Regan A. O’Neil

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...

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