Dec. 20, 2023 – The federal government has set January 22, 2024, as the effective date for new rules that will require non-exempt private corporations existing under the Canada Business Corporations Act (CBCA) to regularly report to Corporations Canada information regarding individuals who have significant...
Private Client
The CRA’s New Power to Compel Oral Interviews
Jan. 17, 2023 – The Canada Revenue Agency (CRA) can now require taxpayers or any other person to answer “all proper questions” and provide all reasonable assistance for any purpose relating to the administration or enforcement of the Income Tax Act (ITA), including by submitting to oral questioning at a place...
Two Davies Partners Selected to Private Client Global Elite Directory
Dec. 21, 2022 – Elie Roth has been named to the Global Elite list and Ray Rubin has been named a Rising Leader in the Private Client Global Elite Directory . Elie is trusted counsel to many high-net-worth individuals and family offices. His leading practice concentrates on all aspects of private client...
Davies Scores Top Ranking in Chambers High Net Worth 2022
July 15, 2022 – Chambers and Partners has once again ranked Davies in Band 1 for Private Wealth Law–Canada in the 2022 edition of Chambers High Net Worth . One source quoted in the guide describes the team as “fantastic” and “incredibly hard-working. ” Another commentator praised the team's “particularly strong...
Corporate Transparency: What’s Happening Across Canada?
July 12, 2022 – Recent amendments to the Canada Business Corporations Act (CBCA) will require private corporations to report information regarding individuals with significant control to Corporations Canada. These amendments form part of the federal government’s long-term corporate transparency objective to...
Revised U.S. Tax Proposals Will Affect Foreign Investment
Nov. 08, 2021 – The U.S. House Committee on Rules recently released an updated version of the Build Back Better Act (Act) to reflect the White House’s Build Back Better framework (Framework) announced on the same day (October 28, 2021). The Framework reflects a significant reduction in the scope of the Biden...
Davies Maintains Top Ranking in Chambers High Net Worth 2021
July 22, 2021 – Chambers and Partners has once again ranked Davies in Band 1 for Private Wealth Law – Canada in the 2021 edition of Chambers High Net Worth . According to the guide, one source who often works with the team on private wealth matters said Davies has “an impeccable reputation,” adding that our...
Disclosure Rules for Nominee Contracts Come into Force in Québec
Oct. 02, 2020 – Bill 42, An Act to give effect to fiscal measures announced in the Budget Speech delivered on 21 March 2019 and to various other measures was assented to on September 24, 2020, bringing into force the new rules respecting the disclosure of nominee contracts to Revenu Québec (RQ ). The purpose of...
Davies Secures Top Ranking in Chambers High Net Worth 2020
July 10, 2020 – Affirming our reputation as market leaders in advising high-net-worth clients, the 2020 Chambers High Net Worth guide has once again ranked Davies in Band 1 for Private Wealth Law – Canada. According to the guide, Davies is described as a “top-tier firm,” with one interviewee commenting, “I have...
CRA Provides Relief from International Income Tax Issues Raised by COVID-19 Travel Restrictions
June 30, 2020 – The COVID-19 pandemic has resulted in the imposition of safety measures by governments around the world, including that in Canada, to protect the health of their citizens. Similarly, businesses have imposed safety measures to protect their employees. These measures include restrictions on travel...
May 20, 2020 – In The Toronto-Dominion Bank v Queen (2020 FCA 80), the Federal Court of Appeal (FCA) confirmed a Federal Court (FC) decision and ruled that a secured creditor had a statutory obligation to pay the Canada Revenue Agency (CRA) for a tax debt of an arm’s-length borrower because the secured...
Estate Planning in Turbulent Times
Apr. 29, 2020 – With more than two-thirds of all Canadians self-isolating in a collective effort to flatten the COVID-19 curve of infection, estate planning is one of a number of planning considerations that are top of mind. Regardless of whether individuals already have a plan in place or have yet to commence...
IRS Issues New Final and Proposed Regulations Under the U.S. Base Erosion and Anti-Abuse Tax
Dec. 10, 2019 – Summary The IRS released final and proposed regulations providing further guidance and addressing certain open issues under the base erosion and anti-abuse tax (BEAT). The final regulations, based partly on the IRS’s response to comments received, clarify previously proposed regulations, such as...
Davies Repeats Top Ranking in Chambers High Net Worth 2019
July 12, 2019 – Recognizing our reputation as market leaders in advising high-net-worth clients, the 2019 Chambers High Net Worth guide has once again ranked Davies as Band 1 for Private Wealth Law – Canada. The guide notes that Davies has “always had a reputation for being one of the best in the area,” with...
Canada Enacts the OECD-Sponsored Multilateral Instrument
June 26, 2019 – Canada has enacted into law the OECD-sponsored Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The enactment of June 21, 2019 represents the penultimate step in the domestic ratification of the MLI in Canada, which will be...
CRA’s Audit Powers Have Limits: Challenging Excessive Requests for Information
June 25, 2019 – In three recent decisions, the courts have curtailed the Canada Revenue Agency’s (CRA’s) broad interpretation of its audit powers and, in so doing, have armed taxpayers with the legal means to push back against excessive or unreasonable requests for information (RFIs) by the CRA. First, in Canada...
IRS Proposes New Rules for Withholding on Interest Transfers in Certain Partnerships
May 13, 2019 – The landmark U.S. tax reform legislation that was enacted at the end of 2017 contained a new federal income tax on gain realized by a foreign seller on the transfer of an interest in a partnership that is engaged in a U.S. trade or business. This measure reversed a court decision that had...
The CRA Cannot Compel Oral Interviews During an Audit
Apr. 10, 2019 – In Minister of National Revenue v Cameco Corporation , the Federal Court of Appeal (FCA) dismissed the Minister of National Revenue’s appeal and held that the Canada Revenue Agency’s (CRA’s) audit powers under the Income Tax Act (ITA) do not extend to compelling taxpayers to be subjected to oral...
Canadian and U.S. Tax Laws: A Review of 2018 and a Look Ahead to 2019
Jan. 31, 2019 – In our annual Tax Review and Outlook report, we look back at significant developments in the Canadian and U.S. tax landscapes in 2018 and offer our predictions on what to expect in 2019. Key Canadian Developments in 2018 Budget 2018 scaled back controversial initiative on taxation of...
Canadian Tax Laws: A Review of 2018 and a Look Ahead to 2019
Jan. 31, 2019 – Each year at this time we offer a look back at some of the more significant income tax developments in Canada affecting domestic and international business over the past year and a look ahead to possible Canadian tax developments in the coming year. Legislative Developments in 2018 Budget 2018 ...
U.S. Tax Laws: A Review of 2018 and a Look Ahead to 2019
Jan. 31, 2019 – Review of U.S. Tax Developments in 2018 U.S. taxpayers will remember 2018 as the year spent coming to terms with the tax reform legislation enacted at the end of 2017, known as the Tax Cuts and Jobs Act (TCJA). The TCJA included a surprisingly large number of new tax rules that have...
Three Davies Partners Recognized in Who’s Who Legal: Private Client 2018
Dec. 20, 2018 – Davies partners Elie Roth , Rhonda Rudick and Tim Youdan have been recognized among the world’s leading Private Client lawyers by Who’s Who Legal 2018. The guide commends Elie for being a “top name in Canada for sophisticated private client advice” who offers “a variety of tax planning and...
U.S. Treasury Broadly Expands Disclosures of “All Cash” Real Estate Purchases
Nov. 28, 2018 – In a previous e-communication , we reported that the Financial Crimes Enforcement Network (FinCen) of the U.S. Treasury Department had established a temporary program that required new disclosures by title insurance companies. The program is part of FinCen’s effort to gather data that will...
Three Davies Partners Honoured in Chambers High Net Worth 2018
July 20, 2018 – Davies’ market leadership and expertise in advising high-net-worth clients has been reaffirmed in the 2018 edition of Chambers High Net Worth . Three Davies lawyers are recognized in this year’s guide: Tim Youdan Elie Roth Rhonda Rudick Published annually, the Chambers High...
Elie Roth Named to 2018 Private Client Global Elite List
July 19, 2018 – Davies partner Elie Roth has been named for the second time to the Private Client Global Elite list published by Legal Week . A partner in the Tax practice, Elie advises high-net-worth individuals and a wide array of private and public clients on all aspects of domestic and international tax...
Department of Finance Releases Revised Income Splitting Rules
Dec. 13, 2017 – Earlier this year, the Department of Finance released a set of far-reaching proposals affecting the taxation of private businesses and their shareholders. Only Rip Van Winkle missed the firestorm reaction to these proposals from a broad range of affected parties. Ultimately, the Government...
Forty-nine Davies Lawyers Recognized in Who’s Who Legal: Canada
Oct. 24, 2017 – Law Business Research’s Who’s Who Legal: Canada 2017 names 49 Davies partners as leading lawyers, including eight Most Highly Regarded practitioners, across 18 different practice areas. Who’s Who Legal nominees are selected on the basis of comprehensive, independent surveys conducted among...
Three Davies Partners Honoured in the Chambers High Net Worth Guide
Sept. 15, 2017 – Davies’ market leadership and expertise in advising high-net-worth clients have been reaffirmed in the 2017 edition of Chambers High Net Worth . Three Davies lawyers are recognized in this year’s guide: Tim Youdan Elie Roth Rhonda Rudick This is the second year that Chambers...
Tax Proposals Target Canadian Business Owners
Aug. 04, 2017 – Although Canadian individuals are already subject to some of the highest tax rates in the world, the Canadian federal government released a discussion paper for consultation on July 18, 2017 which includes proposals that would substantially increase taxes paid by Canadians who carry on business ...
Canadian Government Proposes Major Changes to the Taxation of Private Corporations
July 18, 2017 – The Canadian Department of Finance released a discussion paper earlier today on tax planning using private corporations. Included with the paper is draft legislation for a couple of the matters discussed in the paper. Finance has requested comments on the discussion paper by October 2, 2017. ...
IRS Issues Broad Disclosure Rules for Foreign-Owned Disregarded U.S. Entities
Dec. 15, 2016 – In the flood of guidance being issued in the waning days of the Obama administration, the IRS and Treasury Department have finalized regulations that require foreign owners of single-member U.S. LLCs to file an information return on IRS Form 5472, “Information Return of a 25% Foreign-Owned U.S. ...
Chambers Canada 2017 Recognizes Davies as a Leader in 24 Practice Areas
Oct. 12, 2016 – Davies was recognized as one of Canada’s top law firms by Chambers & Partners in Chambers Canada: Canada’s Leading Lawyers for Business . Once again, Davies leads Canada’s 30 largest law firms with the highest percentage of lawyer rankings, as well as the highest percentage of lawyers ranked and...
Davies Recognized as a Leader in Chambers Canada 2016
Oct. 13, 2015 – Davies Ward Phillips & Vineberg LLP has been recognized as one of Canada’s top law firms by Chambers & Partners in the first edition of Chambers Canada: Canada’s Leading Lawyers for Business . Davies has the highest percentage of lawyer rankings as well as the highest percentage of Band 1...
