The Canadian Department of Finance introduced draft legislation in the 2023 Canadian Federal Budget (Budget 2023) to create employee ownership trusts (EOTs) to facilitate the transfer of a business to the employees of the...more
With the enactment of Bill C-47 on June 22, 2023, Canada's enhanced mandatory disclosure rules are now fully in effect. These rules, which were first announced in the 2021 Canadian federal budget...more
There is a growing international movement to increase employee ownership of businesses. Some jurisdictions such as the United Kingdom and the United States have developed tax rules and incentives to facilitate business...more
The 2023 Canadian Federal Budget, released March 28, 2023 (Budget 2023), proposes significant amendments to expand the application of Canada's general anti-avoidance rule (GAAR). These proposals come after the federal...more
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
The World Health Organization declared the COVID-19 outbreak a pandemic on March 11, 2020, and many employers responded by requiring or encouraging their employees to work from home. Even as Canada commences "reopening", it...more
On February 12, 2020, the Federal Court of Appeal (FCA) in Canada v Alta Energy Luxembourg S.A.R.L., 2020 FCA 43 [Alta Lux] concluded that the Canada-Luxembourg tax treaty (Can-Lux Treaty) was not abused when a Luxembourg...more
2/27/2020
/ Anti-Avoidance ,
Capital Gains ,
Corporate Taxes ,
GAAR ,
Income Taxes ,
International Tax Issues ,
OECD ,
Principal Purpose Test ,
Private Equity Firms ,
Tax Treaty ,
Withholding Tax
Roughly one year after U.S. tax reform, the Department of Finance has introduced amendments to Canada's income tax laws aimed at encouraging investment in Canada. The proposed changes included in the Fall Economic Statement...more
12/5/2018
/ Canada ,
Charitable Donations ,
Corporate Taxes ,
Foreign Investment ,
Incentives ,
Income Taxes ,
Investment Tax Credits ,
Mineral Exploration ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Incentives
The Tax Court of Canada recently held, in Alta Energy Luxembourg SARL v R, 2018 TCC 152, that a Luxembourg S.A.R.L was entitled to treaty benefits on capital gains and that the general anti-avoidance rule ("GAAR") did not...more
Since the decision of the Supreme Court of Canada in Daishowa-Marubeni International Ltd. v. Canada, 2013 SCC 29 [Daishowa], clarity exists for how a vendor treats abandonment obligations on the sale of resource...more