Recent Canadian DevelopmentsIFA 2018 International Tax Conference, May 15 and 16, 2018Recent Canadian Developments
TITLE | CITATION | |
The Cameco Transfer Pricing Decision: A Victory for the Rule of Law And the Canadian Taxpayer | Tax Notes International – Volume 92, Number 9,November 26, 2018, p. 877 | The Cameco Transfer Pricing Decision: A Victory for the Rule of Law and the Canadian Taxpayer |
Taxpayer Wins Convincing Decision in Landmark Canadian Transfer Pricing Case | BLG Bulletin, Tax, October 1, 2018 | Taxpayer Wins Convincing Decision in Landmark Canadian Transfer Pricing Case |
Loosely tossing around allegations of tax avoidance could imperil your credibility | The Globe and Mail, April 19, 2018 | Loosely tossing around allegations of tax avoidance could imperil your credibility |
Canadian Appeals Court Reaffirms Common Interest Privilege | Tax Notes International – Volume 90, Number 2, April 2, 2018, p. 221 | Canadian Appeals Court Reaffirms Common Interest Privilege |
Canada Revenue Agency’s Demand For Oral Interviews of Taxpayer’s Employees Refused by Court | Tax Notes International – Volume 87, Number 9, August 28, 2017, p. 901 | Canada Revenue Agency’s Demand For Oral Interviews of Taxpayer’s Employees Refused by Court |
The CRA demands the right to make taxpayers show it how to better audit them | National Post, February 17, 2017 | The CRA demands the right to make taxpayers show it how to better audit them |
Flow-Through Share Financing – Critical to Canadian Mining | Canadian Mining Magazine – Tax Time, Winter 2017 | Flow-Through Share Financing – Critical to Canadian Mining |
Employee Stock Options: Changes Coming? | Canadian Mining Magazine – Tax Time, Winter 2016 | Employee Stock Options: Changes Coming? |
Canadian Thin Capitalization Developments For Foreign Currency Debt | Tax Notes International – Volume 80, Number 11, December 14, 2015, p. 947 | Canadian Thin Capitalization Developments for Foreign Currency Debt |
Canadian Year-End Tax Planning Deadlines for 2015 | Tax Notes International – Volume 80, Number 10, December 7, 2015, p. 851 | Canadian Year-End Tax Planning Deadlines for 2015 |
Rethinking Provincial Resource Taxes | Canadian Mining Magazine – Tax Time, Fall 2015 | Rethinking Provincial Resource Taxes |
Tax Issues on Acquiring a Canadian Business (with Kim Maguire) | Tax Notes International, Volume 79, Number 9, August 31, 2015, p. 775 | Tax Issues on Acquiring a Canadian Business |
Corporations shouldn’t have to do the CRA’s analysis | The Globe and Mail, August 31, 2015 | Corporations shouldn’t have to do the CRA’s analysis |
Canada Revenue Agency Declares Open Season on Taxpayer Information | Tax Notes International, Volume 79, Number 2, July 13, 2015, p. 143 | Canada Revenue Agency Declares Open Season on Taxpayer Information |
Canada Revenue Agency Forces Taxpayer to Disclose Discussions With Accountant | Tax Notes International, Volume 78, Number 6, May 11, 2015, p. 553 | Canada Revenue Agency Forces Taxpayer to Disclose Discussions With Accountant |
The Paragraph 88(1)(d) Bump: Planning, Pitfalls and Developments | 19th Taxation of Corporate Reorganization Conference, January 20, 21 & 22, 2015 | The Paragraph 88(1)(d) Bump: Planning, Pitfalls and Developments |
Canadian Tax Planning Deadlines for 2014 | Tax Noties International, Volume 76, Number 10, December 8, 2014, p. 911 | Canadian Tax Planning Deadlines for 2014 |
Lawyer-Client Privilege | Canadian Mining Magazine – Tax Time, Fall 2014 | Lawyer-Client Privilege |
Canada Releases Revised Back-to-Back Loan Rules | Tax Notes International, Volume 76, Number 4, October 27, 2014, p. 357 | Canada Releases Revised Back-to-Back Loan Rules |
An Analysis of Canada’s Latest International Tax Proposals | Tax Notes International, Volume 75, Number 13, September 29, 2014, p. 1131 | An Analysis of Canada’s Latest International Tax Proposals |
Canada’s Problematic Proposed New Loan Rules | Tax Notes International, Volume 74, Number 5, May 5, 2014, p. 441 | Canada’s Problematic Proposed New Loan Rules |
Canada to Unilaterally Override Tax Treaties with Proposed New Anti-Treaty-Shopping Rule | Tax Notes International, Volume 73, Number 9, March 3, 2014, p. 797 | Canada to Unilaterally Override Tax Treaties with Proposed New Anti-Treaty-Shopping Rule |
The Paragraph 88(1)(d) Bump: Planning, Pitfalls and Developments | 18th Taxation of Corporate Reorganization Conference, January 29, 30 & 31, 2014 | The Paragraph 88(1)(d) Bump: Planning, Pitfalls and Developments |
Taxation Policies Key to Mining in the Far North | Canadian Mining Magazing – Tax Time, 2014 | Taxation Policies Key to Mining in the Far North |
Canadian Tax Developments in 2013 | Global Tax Weekly, Issue 57, December 12, 3013 | Canadian Tax Developments in 2013 |
Canada’s 88(1)(d) Tax Cost Bump: A Guide for Foreign Purchasers | Tax Notes International, Volume 72, Number 10, December 9, 2013, p. 957 | Canada’s 88(1)(d) Tax Cost Bump: A Guide for Foreign Purchasers |
Vendor Disposition Proceeds May Exclude Certain Purchaser Assumed Obligations (with Kim Maguire) | Corporate Finance, 2013 | Vendor Disposition Proceeds May Exclude Certain Purchaser Assumed Obligations |
Canadian tax-planning deadlines for 2013 (with Stephanie Wong) | International Law Office, December 6, 2013 | Canadian tax-planning deadlines for 2013 |
SCC Tax Judgement – Important to Mining Industry | Canadian Mining Magazine, Fall 2013 | SCC Tax Judgement – Important to Mining Industry |
Canadian Tax Planning Deadlines for 2013 | Tax Notes International, Volume 72, Number 6, November 11, 2013, p. 551 | Canadian Tax Planning Deadlines for 2013 |
Crown Appeals Loss in Canadian Outbound Planning Case | Tax Notes International, Volume 72, Number 1, October 7, 2013, p. 26 | Crown Appeals Loss in Canadian Outbound Planning Case |
Supreme Court Dismisses Appeal in Amalgamation Case | Tax Notes International, Volume 71, Number 14, September 30, 2013, p. 1278 | Supreme Court Dismisses Appeal in Amalgamation Case |
Canada Releases Foreign Affiliate Dumping Amendments | Tax Notes International, Volume 71, Number 10, September 2, 2013, p. 864 | Canada Releases Foreign Affiliate Dumping Amendments |
Cross-Border Loss Utilization | 2013 International Fiscal Association Annual Conference (panel discussion), August 25-30, 2013 | Cross-Border Loss Utilization |
Fair for All? Quebec Raises Mining Taxes (with Kevin Bianchini) | Canadian Mining Magazine, Summer 2013 | Fair for All? Quebec Raises Mining Taxes |
Mining Sector Tax Measures in 2013 Federal Budget | Canadian Mining Magazine, Summer 2013 | Mining Sector Tax Measures in 2013 Federal Budget |
Supreme Court Refuses to Hear Break Fee Appeal | Tax Notes International, Volume 70, Number 6, May 6, 2013, p. 504 | Supreme Court Refuses to Hear Break Fee Appeal |
Tax Structuring for Canadian Investment in Latin American Mining Projects (with Michael Colborne) | Rocky Minteral Law Foundation Special Institute on International Mining and Oil & Gas Law, Development and Investment, April 22-24, 2013 | Tax Structuring for Canadian Investment in Latin American Mining Projects |
Canadian Court Pulls Plug on GAAR Appeal | Tax Notes International, Volume 70, Number 4, April 22, 2013, p. 302 | Canadian Court Pulls Plug on GAAR Appeal |
The Essentials of the Taxation of Mining in Nunavut | Nunavut Mining Symposium 2013 | The Essentials of the Taxation of Mining in Nunavut |
New tax issues for foreign buyers | International Law Office, March 6, 2013 | New tax issues for foreign buyers |
Tax Court compels disclosure in GAAR case | CBA PracticeLink Bulletin, February, 2013 | Tax Court compels disclsoure in GAAR case |
Tax Court compels disclosure in GAAR case | International Law Office, February 22, 2013 | Tax Court compels disclsoure in GAAR case |
Spin-outs in M&A: bridging the valuation gap (with Paul Mingay) | International Law Office, February 6, 2013 | Spin-outs in M&A: bridging the valuation gap |
Physical Presence Determines Where Duties Are Performed, CRA Says | Tax Notes International, February 4, 2013, p. 429 | Physical Presence Determines Where Duties are Performed, CRA Says |
Taxpayer Appeals Break Fee Case to Supreme Court | Tax Notes International, February 4, 2013, p. 428-429 | Taxpayer Appeals Break Fee Case to Supreme Court |
Reviewing the significant tax developments of 2012 | International Law Office, January 25, 2013 | Reviewing the significant tax developments of 2012 |
Tax Court Compels Disclosure in GAAR Case | Tax Notes International, Volume 69, Number 3, January 21, 2013, p. 238 | Tax Court Compels Disclosure in GAAR Case |
2012: The Year in Review (Canada) (with Stephanie Wong) | Tax Notes International, Volume 68, Number 13, December 24, 2012, p. 1191 | 2012: The Year in Review (Canada) |
New Foreign Affiliate ‘Dumping’ Rules Constitute Major Canadian Tax Policy Change | Tax Notes International, Volume 68, Number 12, December 17, 2012, p. 1145 | New Foreign Affiliate Dumping Rules Constitute Major Canadian Tax Policy Change |
Federal Court of Appeal Confirms Tax Treatment of Break Fees | Tax Notes International, Volume 68, Number 10, December 3, 2012, p. 890 | Federal Court of Appeal Confirms Tax Treatment of Break Fees |
Canadian Year-End Tax Planning Deadlines for 2012 (with Stephanie Wong) | Tax Notes International, Volume 68, Number 7, November 19, 2012, p. 747 | Canadian Year-End Tax Planning Deadlines for 2012 |
CRA Reverses Position on Cross-Border Stock Options | Tax Notes International, Volume 68, Number 9, November 26, 2012, p. 801 | CRA Reverses Position on Cross-Border Stock Options |
Canada Revenue Agency’s Foreign Spinoff Guidance | Tax Notes International, Volume 68, Number 1, October 1, 2012, p. 111 | Canada Revenue Agency’s Foreign Spinoff Guiance |
October 15, 2012 Draft Legislation Targets Foreign-owned Canadian Companies | Corporate Tax Planning Series: Corporate Finance, Vol. 18, No. 2 | October 15, 2012 Draft Legislation Targets Foreign-owned Canadian Companies |
Foreign multinationals: beware new Canadian ‘debt dumping’ proposals | International Bar Association, Legal Division, Taxes Newsletter, September 2012 | Foreign multinationals: beware new Canadian ‘debt dumping’ proposals |
Foreign Exchange Tax Treatment: Planning for International Transactions in Volatile Currency Markets | Taxation of Corporate Finance and Financial Structures, June 5, 2012 | Foreign Exchange Tax Treatment: Planning for International Transactions in Volatile Currency Markets |
Eye on Business: Federal government adjusts mining tax credits | CIM Magazine, June/July, 2012 | Eye on Business: Federal government adjusts mining tax credits |
Trends in Canadian Tax: Tightening the Net (with Patrick Lindsay and Salvatore Mirandola) | The Canadian Business Journal, June 12, 2012 | Trends in Canadian Tax: Tightening the Net |
How to Consolidate Tax Losses of a Related Corporation | The Canadian Business Journal, June 12, 2012 | How to Consolidate Tax Losses of a Related Corporation |
Supreme Court to Hear Appeal in Amalgamation Case | Tax Notes International, Volume 66, Number 13, June 25, 2012, p. 20 | Supreme Court to Hear Appeal in Amalgamation Case |
Supreme Court Grants Taxpayer Leave To Appeal in Daishowa | Tax Notes International, Volume 66, Number 11, June 11, 2012, p. 1006 | Supreme Court Grants Taxpayer Leave to Appeal in Daishowa |
Supreme Court Will Not Hear Appeal In Stock Options Case | Tax Notes International, Volume 66, Number 10, June 4, 2012, p. 911 | Supreme Court Will Not Hear Appeal in Stock Options Case |
Caselaw Update, 2nd Understanding Natural Resources Taxation | Federated Press Conference, May 23, 2012 | 2nd Understanding Natural Resources Taxation |
Inbound Financing and Investments, 2012 Mining Taxation Update | Acumen Information Conference, May 10, 2012 | Inbound Financing and Investments, 2012 Mining Taxation Update |
News Analysis: Supreme Court Holds Off on Daishowa | Tax Notes International, Volume 66, Number 6, May 7, 2012, p. 514 | News Analysis: Supreme Court Holds off on Daishows |
Canadian 2012 Federal Budget: Tightening the Screws | Tax Notes International, Volume 66, Number 3, April 16, 2012, p. 247 | Canadian 2012 Federal Budget: Tightening the Screws |
Canada’s Section 116 System for Nonresident Vendors of Taxable Canadian Property (with Marie-Eve Gosselin) | Tax Notes International, Volume 66, Number 2, April 9, 2012, p. 175 | Canada’s Section 116 System for Nonresident Vendors of Taxable Canadian Property |
Using Tax Losses Within a Canadian Group of Companies | Tax Notes International, Volume 66, Number 1, April 2, 2012, p. 59 | Using Tax Losses Within a Canadian Group of Companies |
Timber! Consequences of Assuming Reforestation Obligations (with Michael Colborne) | Canadian Tax Journal, Volume 60, Number 1, 2012 | Timber! Consequences of Assuming Reforestation Obligations |
Canada Extends Transition Period For Treaty-Reduced Nonresident Withholding | Tax Notes International, Volume 65, Number 9, February 27, 2012, p. 687 | Canada Extends Transition Period For Treaty-Reduced Nonresident Withholding |
Supreme Court Again Denies Review In Antle | Tax Notes International, Volume 65, Number 7, February 13, 2012, p. 500 | Supreme Court Again Denies Review In Antle |
The 88(1)(d) Bump: Planning, Pitfalls & Developments | 16th Taxation of Corporate Reorganizations Conference, January 12, 2012 (Federated Press) | The 88(1)(d) Bump: Planning, Pitfalls & Developments |
Important Deadlines Nearing for Canadian Taxpayers | Worldwide Tax Daily, Tax Analysts, December 20, 2011 | Important Deadlines Nearing for Canadian Taxpayers |
2011: The Year in Review (Canada) | Tax Notes International, Volume 64, Number 12, December 19, 2011, p. 872 | 2011: The Year in Review (Canada) |
Canadian Appellate Court Issues Split Decision on Transferred Liabilities | Tax Notes International, Volume 64, Number 2, October 10, 2011, p. 108 | Canadian Appellate Court Issues Split Decision on Transferred Liabilities |
Foreign Exchange Tax Treatment: Planning for International Transactions in Volatile Currency Markets | Taxation of Corporate Finance and Financial Structures, June 21, 2011 (Acumen Information Services) | Foreign Exchange Tax Treatment: Planning for International Transactions in Volatile Currency Markets |
2011 Federal Budget Mostly Unchanged | Tax Notes International, June 20, 2011, Volume 62, Number 12, p. 940 | 2011 Federal Budget Mostly Unchanged |
Voters Reelect Conservative Government | Tax Notes International, Volume 62, Number 6, May 9, 2011, p. 463 | Voters Reelect Conservative Government |
Tax Measures in Canadian Budget May Have to Wait | Tax Notes International, Volume 62, Number 2, April 11, 2011, p. 80 | Tax Measurers in Canadian Budget May Have to Wait |
Canadian Taxation of Mining | Tax Notes International, Volume 60, Number 11, December 13, 2010, p. 867 | Canadian Taxation of Mining |
Tax Executives Urge Group Loss Relief for Canada | Tax Notes International, Volume 60, Number 4, October 25, 2010, p. 231 | Tax Executives Urge Group Loss Relief for Canada.pdf |
Draft Legislation Would Fix Nonresident Tax Trap | Tax Notes International, Volume 59, Number 13, September 27, 2010, p. 1009 | Draft Legislation Would Fix Nonresident Tax Trap.pdf |
Canada Sets Policy on Accessing Accountant’s Working Papers | Tax Notes International, Volume 58, Number 12, June 21, 2010, p. 935 | Canada Sets Policy on Accessing Accountants’ Working Papers.pdf |
Canada Will Not Appeal Ruling on LLC’s Treaty Rights | Tax Notes International, Volume 58, Number 7, May 17, 2010, p. 412 | Canada Will Not Appeal Ruling on LLC’s Treaty Rights.pdf |
Canadian LLC Ruling Overturns Long-Standing Policy | Tax Notes International, Volume 58, Number 3, April 19, 2010, p. 199 | Canadian LLC Ruling Overturns Long-Standing Policy.pdf |
Canada’s 2010 Budget Heavy with Major Tax Initiatives | Tax Notes International, Volume 57, Number 12, March 22, 2010, p. 1021 | Canada’s 2010 Budget Heavy with Major Tax Initiatives.pdf |
The Taxation of Mobile Activities | Bulletin for International Taxation, Volume 61, No. 1, January 2010, pp. 45-50 | The Taxation of Mobile Activities |
Thoughts on the New LOB Clause in the Canada-U.S. Treaty | Tax Notes International, Volume 56, Number 1, October 5, 2009, p. 39 | Thoughts on the New LOB Clause in the Canada-US Treaty.pdf |
Withholding Decision Creates Windfall for Revenue Canada (with David Gaskell) | Tax Notes International, Volume 55, Number 8, August 24, 2009, p. 600 | Withholding Decision Creates Windfall for Revenue Canada.pdf |
Canada Updates Policy on Assessing Working Papers | Tax Notes International, Volume 55, Number 3, July 20, 2009, p. 172 | Canada Updates Policy on Assessing Working Papers.pdf |
Multinational Groups with Canadian Members in Hard Times (with Susan Wooles) | Tax Notes International, Volume 55, Number 3, July 20, 2009, p. 225 | Multinational Groups with Canadian members in Hard Times.pdf |
Further Clarification on Revised Regime for Non-resident Vendors | Tax Notes International, Volume 55, Number 1, July 6, 2009, p. 21 | Further Clarification on Revised Regime.pdf |
The OECD Discussion Draft on Transfer Pricing Aspects of Business Restructurings – Canadian Considerations(with Richard Tremblay) | Tax Management International Journal, Volume 28, Number 2, February 13, 2009, p. 98 | The OECD Discussion.PDF |
Canadian Budget Delivers Outbound Tax Relief | Tax Notes International, Volume 53, Number 5, February 2, 2009, p. 383 | Canadian Budget Delivers Outbound Tax Relief.pdf |
Canada’s Revised Section 116 Regime for Non-resident Vendors (with David Gaskell) | Tax Notes International, Volume 53, Number 4, January 26, 2009, p. 321 | Canada’s Revised Section 116 Regime for Non-resident Vendors.pdf |
Canadian Taxation of Foreign Exchange Gains and Losses (with Byron Beswick) | Tax Notes International, Volume 53, Number 2, January 12, 2009, p. 157 | Canadian Taxation of Foreign Exchange Gains and Losses.pdf |
Ten Essential Elements of Canada’s Tax System(with Susan Wooles) | Tax Notes International, Volume 51, Number 10, September 8, 2008, p. 825 | Ten Essential Elements of Canada’s Tax System.pdf |
Canada’s Taxation of Stock Option Benefits: Could the SDL Remission Order Benefit Others? | Tax Notes International, Volume 49, Number 9, March 3, 2008, p. 777 | Canada’s Taxation of Stock Option Benefits.pdf |
Canada’s 2008 Budget is Light on Business Tax Measures | Worldwide Tax Daily, Tax Analysts, February 28, 2008 | Canada’s 2008 Budget is Light on Business Tax Measures.pdf |
Using Exchangeable Shares in Inbound Canadian Transactions (with Pooja Samtani) | Tax Notes International, Volume 48, Number 13, December 24, 2007, p. 1281 | Using Exchangeable Shares in Inbound Canadian Transactions.pdf |
New 88(1) Comfort Letter Address Bump Anomaly | Canadian Current Tax, Volume 18, Number 1, October 2007, p. 1-5 | New 88(1) Comfort Letter Addresses Bump Anomaly.PDF |
Canada Makes Major Revisions to Interest Proposals | Tax Notes International, Volume 46, Number 8, May 21, 2007, p. 1-5 | Canada Makes Major Revisions to Interest Proposals.pdf |
Canadian Budget has Cross-Border Focus | Tax Notes International, Volume 45, Number 12, March 26, 2007, p. 1166 | Canadian Budget Has Cross-Border Focus.pdf |
Tax Aspects of Debt Settlement: A Primer | Insolvency News, February 2007, p. 15 | Tax Aspects of Debt Settlement A Primer.pdf |
Canada’s Tax Cost Step-Up: What Foreign Purchasers Should Know | Tax Notes International, Volume 44, Number 10, December 4, 2006, p. 779 | Canada’s Tax Cost Step-Up.pdf |
Tax Planning with Losses in Canada | Tax Notes International, Volume 39, Number 5, August 1, 2005, p. 451 | Tax Planning with Losses in Canada.pdf |
Finance Minister Presents 2005 Budget | Tax Notes International, Volume 37, Number 10, March 7, 2005, p. 869 | Finance Minister Presents 2005 Budget.pdf |
The Capital Property Dividend Stop-Loss Rules (précis only) | Canadian Tax Journal, Volume 53, Number 1, 2005, p. 269-91 | The Capital Property Dividend Stop-Loss Rules.pdf |
Public Company Non-Butterfly Spinouts (précis only)(with Firoz Ahmed) | Canadian Tax Foundation, 55thAnnual Tax Conference, September 23, 2003, 32:1-63 | Public Company Non-Butterfly Spinouts.pdf |