On March 16, 2011, the Department of Finance released draft legislative proposals designed to counteract the effects of three taxpayer-friendly Federal Court of Appeal (“FCA”) decisions: Collins v. R. (2010 D.T.C. 5028), Lehigh Cement Ltd. v. R. (2010 D.T.C. 5081)...
Have you ever considered whether you can transfer eligible property on a tax-deferred rollover basis for consideration consisting of shares that have not been legally authorized under the articles of the transferee corporation at the time of the transfer? Recently,...
Non-residents of Canada that are eligible for benefits under a tax treaty entered into between Canada and another country will now have to complete a declaration or provide equivalent information to avail themselves of any reduced rate of tax or...
On June 6, 2011, the Minister of Finance Jim Flaherty reintroduced the 2011 Federal Budget (the “Budget”) which was originally tabled on March 22, 2011 without any substantive changes to the tax measures. Planning for tax avoidance is a legitimate...
We are proud to acknowledge the Q1 2011 accomplishments of our M&A practitioners and close colleagues of Miller Thomson’s national corporate tax team. In the first quarter M&A league table rankings, released just after our own Federal Budget Review was...
