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Bennett Jones Leading the Way in Employee Ownership Trusts

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

Supreme Court of Canada Upholds Treaty-Based Canadian Holding Structure

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

Federal Court of Appeal Upholds Treaty-Based Canadian Holding Structure

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

Tax Court Affirms Treaty-Based Canadian Holding Structure

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

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