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...
The Univar Appeal: A Pyrrhic Victory For Indirect Acquisitions in Canada
In this article published in Tax Notes International, Davies partner Nathan Boidman reviews the decision by the Federal Court of Appeal in Univar Holdco Canada ULC v. The Queen, particularly in the context of the 2016 Income Tax Act amendments concerning surplus stripping rules and the general antiavoidance rule on foreign parties’ recovery of funds invested in indirect acquisitions of Canadian targets.
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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...