Tax Notes

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November 10, 2022

Displaying 1-4 of 4

A primer on ABIL claims: Part II

Evelyne Vacy-Lyle

Primer on when you can claim ABIL This article will be the second in a series of articles that discusses the Allowable Business Investment Loss (“ABIL”) within the meaning of the Income Tax Act (Canada) (“Act”). In particular, this article...


The increasing popularity earnouts

Neil Gurmukh

Due to the economic impact of the COVID-19 pandemic and the recent volatility of stock markets, we have noticed an increased perceived valuation gap between vendors and purchasers in the context of M&A transactions. As a result, contingent consideration arrangements...


Is the burden of proof in tax litigation always on the taxpayer?

Marie-Hélène Tremblay

Burden of proof is a complex subject in Canadian tax litigation and has been heavily debated in recent years. While many mistakenly think the concept can be summarized by the often-heard phrase “the burden of proof in tax matters is...


Implementation of enhanced trust reporting requirements delayed one year

Brittany Sud, Stephen Sweeney

We previously wrote on Finance Canada’s proposed expansion of the reporting requirements for Canadian trusts, including the proposed expansion of the rules to capture bare trust arrangements. You can read our latest article here. The new filing and reporting requirements...


Displaying 1-4 of 4