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FCA emphasizes sparing use of tax remission orders in Internorth case

FCA emphasizes sparing use of tax remission orders in Internorth case

Remission orders as a means of tax debt relief only apply in extraordinary circumstances, as substantiated by the decision on a recent case.

Late filing of pre-acquisition surplus elections

Late filing of pre-acquisition surplus elections

The International Fiscal Association provides insight on CRA’s discretionary power to accept a late pre-acquisition surplus election.

Foreign affiliate dumping rules pose challenge to private equity funds

Foreign affiliate dumping rules pose challenge to private equity funds

The Joint Committee on Taxation addressed key challenges private equity funds face in applying foreign affiliate dumping rules.

New draft legislation released on stock options tax

New draft legislation released on stock options tax

Draft legislations targets large, established firms with proposed cap on deductability of employee stock options.

Ratification of MLI moves forward

Ratification of MLI moves forward

The Multilateral Instrument (MLI) takes effect on October 1, 2019, impacting businesses relying on tax treaties for their tax planning.

FCA affirms application of GAAR to structuring transactions

FCA affirms application of GAAR to structuring transactions

The General Anti-Avoidance Rule (GAAR) may apply to complex tax planning if it is not supported by a commercial purpose.

What can the middle market expect from Alberta's proposed tax cuts

What can the middle market expect from Alberta's proposed tax cuts

With the cuts, Alberta will have the lowest corporate tax rate in Canada, which may benefit businesses beyond a certain income threshold.

  • Heather Forbes
  • |
  • June 11, 2019
CRA sheds light on TOSI excluded business exception

CRA sheds light on TOSI excluded business exception

A recent CRA case clarifies how the “excluded business” exception may apply for private firms evaluating their tax on split income (TOSI).

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Maria Severino

National Tax Leader


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