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Cross-border debt financing - an overview of Canadian tax implications

Cross-border debt financing - an overview of Canadian tax implications

Our authors highlight tax rules that businesses often overlook during cross-border debt financing via shareholder loans.

  • Tracy Li, Jiani Qian, Jennifer Lin
  • |
  • January 22, 2020
Annulment or rectification - what can taxpayers do to address an error

Annulment or rectification - what can taxpayers do to address an error

A recent case signals how opting to annul versus rectify an error may affect the outcome, cost and timeliness of the tax dispute process.

How OECD Pillar One could change international tax processes for MNCs

How OECD Pillar One could change international tax processes for MNCs

The OECD’s proposal to combat taxation challenges arising from the digital economy could have drastic implications for multinational firms.

  • Sean McNama, Wenyan Gu, Jiani Qian
  • |
  • December 18, 2019
Federal fuel charge: Impact on energy sector and Alberta businesses

Federal fuel charge: Impact on energy sector and Alberta businesses

The federal fuel charge and the TIER program aim to work in harmony and will become effective on various taxable fuels on January 1, 2020.

  • Homan Chung, David Crawford
  • |
  • December 17, 2019
2019 year-end tax planner

2019 year-end tax planner

An overview of certain key tax planning issues for business owners, individuals, employees, and corporations in preparation for year end.

  • December 12, 2019
Tax primer on asset versus share sale

Tax primer on asset versus share sale

This article highlights key considerations for the sale of a Canadian private business from both the seller’s and buyer’s perspective.

  • Stephen Rupnarain
  • |
  • December 04, 2019
Increasing assessments and exposure under section 160

Increasing assessments and exposure under section 160

Recent court cases suggest that the CRA is using section 160 – which entails assessing a person for another’s tax debt – more aggressively.

  • Yoni Moussadji
  • |
  • November 27, 2019
Tax consequences of demolition costs in the real estate sector

Tax consequences of demolition costs in the real estate sector

Tax treatment of demolition costs is fact-sensitive and requires an in-depth analysis of the taxpayer’s intent and business considerations.

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Maria Severino

National Tax Leader


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