Category: Tax

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CRA Positions on Deferred Share Unit Plans and Private Health Services Plans

December 7, 2015

In November of this year at the Canadian Tax Foundation’s 67th Annual Tax Conference (Conference), the Canada Revenue Agency (CRA) announced its current positions on Deferred Share Unit (DSU) conversions; payment events for DSU plans that cover U.S. taxpayers; and the requirement that Private Health Services Plans (PHSPs) provide benefits that qualify for the medical expense tax credit. DSU CONVERSIONS The…

Are You Ready? MPAC’s Next Current Assessment is January 1, 2016

November 23, 2015

MPAC’s 2016 CVA for every property in Ontario is just around the corner. Are you ready for January 1, 2016? Property taxes for the next four years, 2017 to 2020, will be based on these values. Our panel of experts will review all of the important issues, including impact on development sites and highest and best-use assessments, whether appealing your…

Rectification in a Tax Context: The Intention Standard Prevails

November 2, 2015

A drafting mistake in an agreement can result in significant and unintended tax consequences. In the recent case of Baytex Energy Ltd. v. Canada (Attorney General) (Baytex), the Court of Queen’s Bench of Alberta (Court) considered whether the equitable remedy of rectification was available to address mistakes in certain written agreements that, if unchanged, could have resulted in tax payable…

Labour Fund Reporting Requirements Enacted

July 28, 2015

  The Income Tax Act was recently amended to enact unprecedented and potentially onerous public disclosure obligations on labour organizations and investment funds in which labour organizations or persons represented by a labour organization have an interest.   The amendment enacts a private member’s bill to amend the Income Tax Act. It imposes unusual public disclosure requirements on labour organizations,…

2015 Federal Budget – Selected Tax Measures

April 22, 2015

  On April 21, 2015, the Minister of Finance presented Canada’s long-awaited 2015 Federal Budget (the 2015 Budget). The 2015 Budget includes a number of taxpayer-friendly measures, including limited relief from Canadian source withholding requirements for some non-resident employers, extension of accelerated tax depreciation rates for machinery and equipment and a phased-in decrease in the small business tax rate. However,…

A Skimmed Plan Nord: Keeping in Line with Quebec’s Current Economic Landscape

April 10, 2015

  The Quebec government first launched its Northern Plan, le “Plan Nord”, in 2011 with great fanfare. The Plan Nord seeks to develop Quebec’s vast territory north of the 49th parallel, which covers 72 per cent of the province or approximately 1.2 million km2. Since the initial announcement, the implementation of the Plan Nord has been stalled in large part…

Government of Québec 2015-16 Budget: A Balanced Budget and Ambitious Economic Plan

March 27, 2015

On March 26, 2015, the Quebec government (Government) unveiled the 2015-16 budget (Budget). After six years of deficits and further to a significant reduction of Government expenses, Quebec is anticipating returning to a balanced budget for 2015-16 and for the future. The balanced budget comes without raising any income taxes, sales taxes or fees. The Budget appears to be designed…

LNG Equipment and Buildings: Canadian Government Proposes Accelerated Writeoff

March 9, 2015

  On February 19, 2015, the Canadian government released draft regulations introducing accelerated capital cost allowance (CCA) for facilities in Canada that liquefy natural gas. The government’s intention is to encourage investment in new facilities to support the liquefied natural gas (LNG) industry in Canada.   The draft regulations provide for an additional 22-per-cent CCA allowance for equipment and structures…

Alert: New Requirement to File Existing GST/HST Closely Related Party Elections Quickly Approaching

November 14, 2014

  Closely related Canadian corporations and partnerships often use an election under section 156 of the Excise Tax Act (Canada) to manage GST/HST on intercompany supplies of services and property (other than real property). The effect of the election is to deem every taxable supply between the electing parties to have been made for no consideration, resulting in no GST/HST…

B.C.’s Draft Legislation to Implement LNG Tax – Many Answers, Some Questions

November 3, 2014

  On October 21, 2014, the B.C. government released draft legislation introducing a liquefied natural gas (LNG) income tax (LNG Tax) on liquefaction activities that take place at LNG facilities in the province. The draft legislation provides details of the proposed new tax and answers questions that were left open in the high level discussion of the tax in the…

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