Tax Notes

October 5, 2010

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International Tax: Tax Information Exchange Agreements – Overview And Update

Most international tax treaties entered into by Canada include a tax information exchange provision (e.g., Article XXVII of the Canada-US Tax Treaty) that enables the Canada Revenue Agency (“CRA”) to obtain pertinent tax information about a particular taxpayer from a...

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New Charity Tax Specific Graduate Degree

Robert B. Hayhoe

Osgoode Hall Law School at York University has launched a new part time Master of Laws (LL.M.) degree specializing in Charities and Not-for-Profit Tax Law. This degree, which we believe to be the first law degree of its kind anywhere...

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Current Cases: Sale Of Business – Defining Goodwill And Defending The Purchase Price Allocation

The Tax Court of Canada decision in Transalta Corporation v. The Queen, 2010 TCC 375 (“Transalta”), is an important addition to the jurisprudence concerning the meaning of goodwill for tax purposes and the application of section 68 of the Income...

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Cross-Border Tax: Canada-US Tax Treaty Update – CRA Views On Treaty Entitlement On Canadian Source Income And Profit For US LLC Shareholders

The Canada Revenue Agency (“CRA”) recently confirmed that it continues to maintain its long-standing position that a US limited liability company (“US LLC”) that is treated as a fiscally transparent entity for US tax purposes is not entitled to treaty...

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Canadian Tax: Update On Restrictive Covenant Proposals

Wendi P. Crowe

On July 16, 2010, the Canadian federal government released further amendments to the draft legislation dealing with payments for non-competition and other restrictive covenants.  These proposals continue to be significant for taxpayers who acquire or dispose of businesses. A Colourful...

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International Tax: The Lehigh Cement Case – Canadian Non-Resident Withholding Tax On Interest Payments

On May 17, 2010, the Federal Court of Appeal (“FCA”) rendered its judgment in Lehigh Cement Limited v. R., 2010 FCA 124 (“Lehigh”), in which it found that the transaction in issue entered into by the corporate taxpayer, Lehigh Cement...

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