Reportable uncertain tax treatment rules
The mandatory disclosure rules contained in Bill C-47 are now in effect. While there has been a great deal of discussion regarding the reportable and notifiable transaction rules, Bill C-47 also introduced new reporting obligations in respect of “reportable uncertain […]
Transfer Pricing 2023 – Canada: Law & Practice and Trends & Developments
Chambers Global Practice Guides: Transfer Pricing
David Chodikoff, Andrew Etcovitch, Carolyn Inglis, Daniel Kiselbach, Shashi Malik, Victoria Rodrigues and Marie-Hélène Tremblay are contributors to the 2023 edition of Chambers Global Practice Guides: Transfer Pricing. Both law & practice and trends & developments are highlighted in this […]
Toronto and Ottawa vacant homes tax: Don’t forget to file your declaration for 2022!
In 2022, Toronto and Ottawa introduced vacant homes tax regimes.[1] These regimes are modelled after the empty homes tax regime introduced in Vancouver in 2017, and are aimed at incentivizing owners of vacant residential properties to sell or rent their […]
Proposed amendments to the foreign affiliate rules
Introduction On August 9, 2022, the Department of Finance (“Finance”) released details of proposed changes to the Income Tax Act (the “ITA”). A number of the proposed changes impact the rules relating to “foreign affiliates” as defined by the ITA. The most […]
Recent changes to pertinent loan or indebtedness (PLOI) elections
On March 25, 2022, the Canada Revenue Agency (the “CRA“) issued a notice to tax professionals outlining certain changes to “pertinent loan or indebtedness” (“PLOI“) elections, including PLOI elections made in respect of cross-border shareholder loans under subsection 15(2.11) of […]
