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Corporate Taxes Canada Privately Held Corporations

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The Digital Services Tax: Canada Takes Aim at Tech Giants

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In the recently released Budget 2021, Canada's federal government announced its plan to continue with the development of a Digital Services Tax (DST) to be imposed on certain large taxpayers. The DST is proposed to apply at a...more

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Canadian Budget Proposes New Cross-border Interest Deductibility Limit

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The 2021 Canadian Federal Budget, released on April 19, 2021, proposes new rules that would fundamentally alter the interest deductibility landscape for Canadian businesses. The thrust of the new rules (referred to herein as...more

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Business Measures in 2019 Federal Budget

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The 2019 Canadian federal budget was released on March 19, 2019 (Budget Day). As many of the proposals are aimed at investing in Canada’s middle class, the Budget was relatively light on proposals affecting businesses....more

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Status of Measures Targeting Private Corporations Following the 2018 Federal Budget

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The Federal Budget, released February 27, 2018, has clarified federal plans to change the tax treatment of private corporations and represents a substantial retreat from proposals announced in July 2017. In July 2017, the...more

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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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Federal Court of Appeal Clarifies Test for “De Facto Control”

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In McGillivray Restaurant Ltd. v. R., the Federal Court of Appeal (FCA) recently provided welcome news to the Canadian tax community concerning the appropriate legal test for determining whether a person has “de facto...more

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