June 2014 Election Deadlines for Retroactive Application of New Foreign Affiliate Reorganization Rules

Auteur : Geoffrey S. Turner

Disponible en anglais seulement.

This article examines the new foreign affiliate reorganization provisions and key elections affecting Canadian corporations with foreign affiliates. It may now be possible for taxpayers to clarify, proactively confirm, or even change the intended tax consequences of historic transactions that closed after December 20, 2002.

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Geoffrey S. Turner
Geoffrey S. Turner

Avocat-conseil senior




Federal Court of Appeal Says Funding Services Not Subject to GST/HST

4 oct. 2019 - Traduction en cours. 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...