Effective January 1, 2024, Canada introduced detailed rules into the Income Tax Act (Canada) to facilitate and encourage employee ownership of small and medium sized Canadian businesses through the creation of employee...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
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
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