Category: Tax

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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…

Selected International Measures from August 2014 Legislative Proposals

September 8, 2014

On August 29, 2014, the Minister of Finance released for consultation draft legislative proposals (August 29 Proposals) to amend the Income Tax Act (Canada) (Act) which would implement certain measures from the 2014 federal budget as well as certain other measures. The government has invited comments by September 28, 2014. It is expected that the government will then introduce these…

Canada and U.K. Agree to Protocol to Amend Tax Treaty

July 22, 2014

On July 21, 2014, a protocol (Protocol) to amend the Canada-U.K. tax treaty (Treaty) was signed in London, England. Negotiations to update the Treaty had been ongoing since the fall of 2011. Key provisions of the Protocol include the following:   The Protocol will generally eliminate the ability of source states to impose withholding tax on interest paid to a…

Government of Québec 2014-15 Budget – Public Financial Discipline Imposed: Impact on Businesses

June 12, 2014

  The goal of the newly elected majority government (Government) is to create both wealth and employment in Quebec. To achieve this goal, the Government needs to end the structural imbalance of public finances. There are two pillars underlying this goal: a growing economy and sound, balanced public finances. The Government has identified five measures for achieving economic prosperity: support…

Federal Court of Appeal Confirms Limited Scope of Foreign Affiliate Anti-Avoidance Rule

April 30, 2014

  OVERVIEW   The Federal Court of Appeal (FCA) released its decision in Canada v. Lehigh Cement Limited (Lehigh Cement) on April 23, 2014. The decision concerned the application of paragraph 95(6)(b) of the Income Tax Act (Canada) (Act), an anti-avoidance provision that targets the manipulation of share ownership in a non-resident corporation in order to obtain favourable tax results. The FCA upheld the…

B.C.’s Proposed LNG Tax – Some Answers, Many Questions

March 3, 2014

  The recent British Columbia budget (the budget) included a basic framework for a new income tax on the liquefaction of natural gas at LNG facilities in the province (LNG Tax). The LNG Tax will apply to LNG that is to be exported from B.C. or consumed in B.C. and to the liquefaction in B.C. of gas produced in B.C….

Selected GST/HST Measures in 2014 Federal Budget

February 21, 2014

  The 2014 Federal Budget (Budget) contained some significant GST/HST changes. Most importantly, it proposes changes to the election contained in section 156 of the Excise Tax Act (ETA), which allows closely related parties to make intercompany supplies on a GST/HST-free basis. These changes are described in further detail below and should be reviewed by all parties to existing and anticipated elections….

2014 Federal Budget – Selected Tax Measures

February 12, 2014

  There is an evident international theme to many of the tax measures included in the 2014 Federal Budget presented by the Minister of Finance on February 11, 2014 (the 2014 Budget). The 2014 Budget includes proposals to address back-to-back loans in the context of the restrictions on the deductibility of interest under the thin capitalization rules as well as…

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