Tax Notes

June 2011

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Cross-Border and International Tax: New Canadian Compliance Requirements for Non-Residents of Canada

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...

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2011 Federal Budget – Focus on Anti-Avoidance Rules

William J. Fowlis

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...

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Miller Thomson’s National M&A Work is Ranked Top Tier Among Canadian Law Firms and Globally

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...

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Legislative Responses to Recent Canadian Tax Cases: Deductibility of Contingent Expenditures, Non-Resident Withholding Tax on Interest, and Segregated Fund Policy Reserves

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)...

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Tax Tip – Share Consideration Issued on a Tax-Deferred Rollover

Bryant D. Frydberg

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,...

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Displaying 1-5 of 5