Tax Topics - July 19, 2012, No. 2106

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In This Issue:

- More on Rectification in Quebec .. 1

- Tax Treaties

Colombia in Force . . 4

Australia Under Negotiations . .4

- Information Circular IC-100 Now IC12-1 .. 4

- Financial Claim Review Manual .. 5

- IPPs Minimum Withdrawals - Registered Plans Administrators .. 5

- Recent Cases .. 5

Excerpt from More on Rectification in Quebec:

Rectification continues to be a topic of heated debate in Quebec. After a series of decisions by the Court of Appeal last year on the subject, the Quebec Superior Court rendered on June 19, 2012 an important judgment (Mac’s Convenience Stores inc. v. Couche-Tard inc., 2012 QCCS 2745) on a motion for declaratory judgment involving a well-known Canadian company. This case is a reminder that rectification is not always available to correct errors made in the planning of a transaction, even if the unintended tax consequences result in a loss of several million dollars for a taxpayer.

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