The European Securities and Markets Authority (“ESMA“) has on April 4, 2018 published a press release which confirms that Canada and South Africa will continue to meet all requirements for endorsement under Art 4(3) of the...more
Historically, Canadian investors in U.S. partnerships benefitted from an extremely efficient income tax structure – i.e., a single level of tax, credit against Canadian taxes for taxes paid in the U.S., and an ability to...more
The Supreme Court of Canada (SCC) released two decisions last week regarding the power of the Canada Revenue Agency (CRA) to demand production of information and documents, including accounting records, from lawyers and...more
The Income Tax Act was recently amended to enact unprecedented and potentially onerous public disclosure obligations on labour organizations and investment funds in which labour organizations or persons represented by a...more
The recent decision in Bolton Steel Tube Co. Ltd. v. The Queen, 2014 TCC 94, confirms that the CRA is required to reassess a taxpayer in accordance with terms of settlement. In its decision, the Tax Court provides useful...more