Oct. 04, 2019 - In SLFI Group v Canada (2019 FCA 217), the Federal Court of Appeal (FCA) overturned a Tax Court of Canada (TCC) decision and ruled that a group of Canadian mutual funds (Funds) was not required to self-assess GST/HST on funding services provided by a U.S. entity, because these services were...
Canada Intent on Stoppin’ the Shoppin’ and More
Canada’s federal budget for 2014 proposed a rule intended to curtail treaty-shopping: the practice of structuring multinational businesses to take advantage of more favourable tax treaties available in certain jurisdictions. This article presents a number of scenarios to describe how application of this proposed rule would play out in differing circumstances, exposing potential problems that might ultimately discourage foreign investment.
Aug. 22, 2019 - As outlined in our e-communications of May 21, 2019, and August 12, 2019, Québec’s Ministry of Finance has introduced new rules regarding the disclosure of nominee agreements. The new disclosure requirement is relevant to nominee agreements involving one or more parties that are subject to Québec tax...