The Minister of National Revenue and Minister of Finance issued a joint statement regarding the Canada Without Poverty decision (2018 ONSC 4147). The main outcome of this decision was that [...]
As a general rule, every Canadian resident who is a shareholder of a “controlled foreign affiliate” (“CFA”), will be subject to tax in Canada on that person’s share of the “foreign accrual [...]
Basic Principles In general terms, paragraph 20(1)(c) of the Income Tax Act (the “Act”) allows a taxpayer to deduct interest expense paid or payable on borrowed money that is used for the purpose [...]
On July 23, 2018, the OECD published its Economic Survey of Canada. Although the OECD projects strong economic growth for Canada, one of the risks it identified is the effects of US tax reform [...]
Today the Department of Finance announced a consultation for a new set of draft tax proposals, relating to income tax, GST/HST, and excise tax. The draft legislation and explanatory notes are [...]
In a recent article that I posted on my Canadian International Tax Blog (http://taxca.com/blog-2018-5/) (“Canadian Trusts with Foreign Beneficiaries Face New Challenges”), I discussed certain [...]
BACKGROUND On July 18, 2017, the Department of Finance (“the Department”) released proposals to amend the income tax treatment of certain businesses and in particular Canadian-controlled private [...]
On May 28, 2018, Canada’s Finance Minister tabled a Notice of Ways and Means Motion aimed at introducing legislation to enact the Multilateral Convention to Implement Tax Treaty Related Measures [...]
The Minister of Finance, Bill Morneau, published new legislative proposals to amend the Excise Tax Act (“ETA”). The amendments introduce new rules regarding the GST/HST treatment of allowances, [...]
The ability to claim credits for foreign taxes (“foreign tax credits”) (“FTC”) is the most fundamental and common way of avoiding double tax in connection with cross-border transactions. Both [...]
