Originally published in Tax Notes International, this article examines the Tax Court of Canada’s CIT judgment, as well as two pending companion cases, and sheds light on how the simple notion underlying controlled foreign corporation attribution rules— that CFCs’ undistributed passive income should be taxed as earned — can evolve into complex, mechanical, and sometimes convoluted rules.
Federal Budget 2024: How It Impacts You and Your Business
Apr. 16, 2024 - On April 16, 2024 (Budget Day) the Honourable Chrystia Freeland, Deputy Prime Minister of Canada and Minister of Finance, delivered the Liberal Party’s federal budget (Budget 2024). Budget 2024 included a number of proposed changes to the Income Tax Act (ITA) and other tax legislation. ...
Governance Insights: 10 Trends that GCs and Boards Need to Know
Jan. 24, 2024 - The latest edition of Davies’ Governance Insights is now available. In this issue, we explore 10 important trends that will help general counsel and boards navigate the year ahead. In order to help you with your strategic and compliance planning, we discuss issues including the...
