The 2023 Canadian Federal Budget, released March 28, 2023 (Budget 2023), proposes significant amendments to expand the application of Canada's general anti-avoidance rule (GAAR). These proposals come after the federal...more
Bare trusts across Canada could soon be required to file annual returns with the Canada Revenue Agency, or face large penalties for failing to report....more
This piece was updated on April 2, 2020.
As part of Canada's COVID-19 Economic Response Plan announced on March 18, 2020, and through subsequent press releases, the Department of Finance and the Canada Revenue Agency have...more
On February 12, 2020, the Federal Court of Appeal (FCA) in Canada v Alta Energy Luxembourg S.A.R.L., 2020 FCA 43 [Alta Lux] concluded that the Canada-Luxembourg tax treaty (Can-Lux Treaty) was not abused when a Luxembourg...more
2/27/2020
/ Anti-Avoidance ,
Capital Gains ,
Corporate Taxes ,
GAAR ,
Income Taxes ,
International Tax Issues ,
OECD ,
Principal Purpose Test ,
Private Equity Firms ,
Tax Treaty ,
Withholding Tax