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Corporate Taxes › Canada › Capital Gains

Bennett Jones LLP

Tax Court Affirms Treaty-Based Canadian Holding Structure

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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

Bennett Jones LLP

Growing Concerns with Proposed Amendments Affecting Private Businesses and their Shareholders

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On July 18, 2017, Minister of Finance Bill Morneau announced sweeping changes to the way private businesses and their shareholders are taxed. The Government's proposals encompass three broad areas: (1) income sprinkling...more

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