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….
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…
February 4, 2014
OVERVIEW The Canada Revenue Agency (CRA) opened its Offshore Tax Informant Program (OTIP) on January 15, 2014. Under the OTIP, the CRA pays eligible informants for certain written information provided only about major cases of international tax evasion or avoidance. This information must lead to the collection of more than C$100,000 of additional federal tax once all rights of…