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...
Metal Streams in Foreign Affiliates
Originally published in the CCH International Tax Newsletter, this article considers the principal features of the typical metal stream transaction that are relevant from a tax perspective. The focus is on the common situation of a Canadian parent company owning a non-Canadian mining property through a foreign affiliate, and selling a metal stream based on the future production from that foreign affiliate’s mining property.
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...