On November 26, 2021, the Supreme Court of Canada (the SCC) released its highly anticipated decision in Canada v Alta Energy Luxembourg SARL, 2021 SCC 49 [Alta Energy Lux], that addressed treaty-based holding structures and...more
The clock is ticking for multinational enterprises and private equity firms with investments in the Canadian resource sector as anti-treaty shopping measures in the OECD's Multilateral Convention to Implement Tax Treaty...more
Since March 18, 2020, the following updates have been released by the Government of Alberta and the Canada Revenue Agency (CRA) regarding their respective economic relief plans to help mitigate the effects of the COVID-19...more
On March 18, 2020, the federal government announced Canada's COVID-19 Economic Response Plan, containing a number of measures to be implemented by the Department of Finance to help manage the financial hardships Canadians are...more
On May 29, 2019, Darcy Moch, Greg Johnson and Jared Mackey of Bennett Jones participated on a witness panel before the Standing Senate Committee on Foreign Affairs and International Trade to discuss the application of Bill...more
5/31/2019
/ Anti-Avoidance ,
BEPS ,
Canada ,
Capital Gains ,
Energy Sector ,
Foreign Investment ,
International Tax Issues ,
OECD ,
Private Equity Firms ,
Tax Treaty ,
Withholding Tax
The 2019 Canadian federal budget was released on March 19, 2019 (Budget Day). As many of the proposals are aimed at investing in Canada’s middle class, the Budget was relatively light on proposals affecting businesses....more
3/25/2019
/ BEPS ,
Canada ,
Corporate Taxes ,
Cross-Border Transactions ,
Federal Budget ,
Foreign Affiliates ,
Mutual Funds ,
Privately Held Corporations ,
Proposed Amendments ,
Tax Avoidance ,
Tax Treaty
The Federal Budget, released February 27, 2018, has clarified federal plans to change the tax treatment of private corporations and represents a substantial retreat from proposals announced in July 2017. In July 2017, the...more
On July 18, 2017, Minister of Finance Bill Morneau announced sweeping changes to the way private businesses and their shareholders are taxed. The Government's proposals encompass three broad areas: (1) income sprinkling...more
In the Canadian Federal Budget released on February 11, 2014, the Department of Finance signaled its intention to enact a domestic treaty-shopping rule, generally allowing the Canada Revenue Agency (CRA) to deny treaty...more
In the March 2013 Federal Budget, the Department of Finance indicated that it intended to initiate a consultation process on certain "treaty shopping" practices. On August 12, 2013, the government released a consultation...more