Originally Published in CCH Canadian Ltd. on March 21, 2013. One might think that it would go without saying, but obviously not, that the Tax Court of Canada is neither a court of equity nor a section 96 court. That...more
The Canada Revenue Agency had an important win this week in its efforts to access information outside of Canada. On March 20, 2013, the Federal Court issued its decision in Soft-Moc Inc. v. M.N.R. 2013 FC 291, dismissing...more
On February 21, 2013, the Federal Court of Appeal released two decisions related to the obligations of the Minister of National Revenue when making ex parte applications under subsection 231.2(3) of the Income Tax Act (the...more
In Johansson-Dohrmann v. CBR Systems, Inc. et al, No. 3:12-cv-01115 (S.D. Cal., filed May 7, 2012), the latest data privacy class action to reach settlement, Judge Michael M. Anello on February 5, 2013 granted preliminary...more
Many of us in banking were glad to see 2012 come to a close and hopeful for a better 2013. To the extent that better means fewer regulatory issues, now is the time to prepare your bank’s Home Mortgage Disclosure Act (“HMDA”)...more
Do you use a third party service to conduct background checks on job applicants or employees? If yes, then you should take note of new forms which employers are required to use for this purpose, effective January 1, 2013. ...more
On February 6, 2013, at the Toronto-Centre Tax Professionals Breakfast Seminar, the Canada Revenue Agency discussed its current strategic activities and priorities and changes to the Scientific Research & Experimental...more
The recent Federal Court of Appeal decision of Edwards v. The Queen (2012 FCA 330) includes an interesting observation dealing with the Canada Revenue Agency’s policy with respect to proposed legislation....more
On January 22, the FFIEC proposed guidance on the applicability of consumer protection and compliance laws, regulations, and policies to activities conducted via social media by federally supervised financial institutions, as...more
The Canada Revenue Agency has now published a set of answers to questions and concerns about the audit process presented to it by the Tax Executives Institute late last year....more
An Indian tax appellate tribunal has recently ruled on the issue of marketing intangibles in a transfer pricing case involving the Indian manufacturing and sales subsidiary of the Korea-based LG Electronics Inc. In that case,...more
This is the eleventh year in which the CRA has issued such a report, which is generally intended to enhance taxpayer awareness of the APA program and to describe (i) current operational status, (ii) relevant changes, and...more
In This Issue: *Financial Industry Developments - OCC Guidance on Transition Periods under Section 716 of the Dodd-Frank Act - CFTC Reporting of Swap Transactions and Swap Dealer Registration - Department...more
On December 19, 2012, the Fed, FDIC and OCC released the annual adjustment to asset-size thresholds used to define small bank, small savings association, intermediate small bank and intermediate small savings association...more
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