Category: Tax

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Quebec 2016-2017 Budget: Continued Fiscal Discipline

March 18, 2016

On March 17, 2016, the Quebec government (Government) unveiled the 2016-2017 budget (Budget). The Government confirmed that it balanced the books for 2015–16 and anticipates maintaining a balanced budget for 2016–17. The balanced budget comes without raising any income taxes, sales taxes or fees. The balanced budget is, however, based on certain important assumptions, including an economic growth of 1.5…

Opportunities for U.S. Private Equity in Canada’s Energy Sector

March 14, 2016

The Canadian energy sector represents a unique investment opportunity for private equity investors seeking to invest in, or acquire outright, established energy assets at a discount to historical prices. The ability to capitalize on the discounted debt of oil and gas companies in a low-risk jurisdiction like Canada has never been more attractive. One of the many factors that make…

Ontario Retroactively Eliminates Land Transfer Tax Exemption for REITs, Other Pooled Investment Vehicles

February 19, 2016

On February 18, 2016, the Ontario Ministry of Finance published retroactive amendments to regulation 70/91 to the Land Transfer Tax Act (Ontario), pursuant to which an acquisition of an interest in a partnership that owns land in Ontario is generally not subject to Ontario land transfer tax so long as the acquirer’s interest in the partnership does not increase by…

Changes to British Columbia Property Transfer Tax

February 17, 2016

On February 16, 2016, the British Columbia government released its 2016 budget (Budget). Contained in this budget were several important changes to the Property Transfer Tax Act (PPTA). INCREASE IN PROPERTY TRANSFER TAX RATE FOR PROPERTY IN EXCESS OF C$2 MILLION The Budget introduced a third property transfer rate of three per cent on the portion of fair market value of…

Look Ahead: 2016 Legal Trends

January 8, 2016

  While global markets can be unpredictable, we have assembled some key legal trends that may help you prepare for what lies ahead in 2016.  ​​​​   Anti-Spam   Capital Markets  ​ China    Commercial Real Estate Cybersecurity Employment & Labour Financial Services Regulatory Intellectual Property International Trade   Litigation & Dispute Resolution   Mergers & Acquisitions   Oil &…

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,…

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