News & Publications Results
Related items for Practice area: Tax.
|Envision: Implications for Canadian Corporations Contemplating a Merger
On September 26, 2013 the Supreme Court released its decision in the Envision case. The case deals with the amalgamation of two credit unions, but has broader implications for the tax treatment of amalgamations in Canada, and will be of interest to Canadian corporations contemplating a merger in the future.
|Lawson Lundell Recognized by Best Lawyers in Canada 2014
Best Lawyers® in Canada 2014 recognizes 39 Lawson Lundell lawyers in 23 practice areas with two lawyers being named Lawyer of the Year. The firm is top-listed in Canada in Aboriginal Law and in British Columbia for Banking and Finance, Employee Benefits Law, Energy Regulatory Law, Public Procurement Law and Private Funds Law. Lawson Lundell is also top-listed in Alberta for Employee Benefits Law and Aboriginal Law and in the Northwest Territories for Personal Injury Litigation and Family Law.
|Reinhold Krahn named Tax Law Lawyer of the Year (Vancouver) by Best Lawyers
Reinhold Krahn has been named Best Lawyers Tax Law Lawyer of the Year in Vancouver for 2013.
|2012 Federal Budget: Changes to the thin-capitalization rules
On March 29, 2012, Canadian Federal Finance Minister Jim Flaherty delivered the government’s 2012 federal budget (the “Budget”). As is typical in Canada, the Budget contained interesting tax policy changes. This article briefly highlights the three most important proposed changes to the thin-cap rules that apply to in-bound Canadian investments.
|Employee Life and Health Trusts and Health and Welfare Trusts
This paper reviews the basic features of Employee Life and Health Trusts (ELHT), considers the most recent statements of the CRA and compares the tax and other advantages and disadvantages of using an ELHT versus a Health and Welfare Trust (HWT).
|Canadian Tax Rates, Not Quite a Tax Haven
This article provides a brief overview of the taxes incurred by a corporation subject to tax in Canada.
|Proposed Amendments to Section 892 Regulations
The IRS has today released proposed amendments to the Code Section 892 regulations. Code Section 892 is the provision within the Internal Revenue Code that exempts foreign sovereigns from taxation in respect of investment income earned in the U.S. The primary amendments are described in this article.
|Overview of the Differences between the U.S. and Canadian Entity Classification Systems
Entity classification refers to a set of rules used in the U.S. tax system to classify entities for the purposes of the Internal Revenue Code. Once classified, the entity will either be subject to the Code rules for corporations or the Code rules for partnerships.
|US Canada Cross-Border Tax: Getting out of Canada
With the U.S. economy not as robust as it once was, it seems that Americans are currently more interested in selling their Canadian assets, particularly recreational property, than buying Canadian assets. It is therefore useful to consider the issues that arise when a U.S. person sells Canadian real estate.
The following points are relevant:
- The U.S. person will be required to prepay tax on any gain arising from the Canadian real estate; and
- If the real estate has been rented, the Canada Revenue Agency (CRA) will require the U.S. person to catch up on any unpaid tax on the rental revenue.
|US Canada Cross-Border Tax: When to Worry About Canada
These days many US businesses are looking north to Canada for new markets. This paper discusses when a US business needs to worry about the Canadian tax system. The short answer comes from some of the oldest provisions in the Income Tax Act. US businesses need to worry about Canadian tax when they have a physical presence in Canada.
|Lawson Lundell represents BC Hydro in the $825 million purchase of a 1/3 interest in the 493 megawatt Waneta Dam from Teck Metals Ltd.
On March 5, 2010, British Columbia Hydro and Power Authority closed the $825 million purchase from Teck Metals Ltd. of a 1/3 interest in Teck’s 493 megawatt Waneta Dam in south-eastern British Columbia.
|Federal Budget 2010 Taxation Measures of Interest to Technology Companies, Private Equity and Venture Capital
The March 4, 2010 Federal Budget introduced some targeted measures of interest to companies in the technology industry, as well as private equity and venture capital funds investing in technology companies.
|Lawson Lundell forms Financial Recovery Group
To better assist our clients through uncertain economic times, Lawson Lundell LLP announces the formation of its Financial Recovery Group.
|“Disclosure and Access to Information British Columbia Taxpayer Perspective”
In British Columbia, as elsewhere, there exists a tension between, on the one hand, the need to disclose sufficient information to complete the roll and to appeal assessments, and on the other hand, the need to protect commercially sensitive information from unnecessary and potentially harmful exposure to competitors. It has generally fallen to the Property Assessment Appeal Board to attempt to strike the balance between these competing interests.
|Real Estate - Special Topics: Expropriation from the Property Owner’s Perspective"
The development of transportation infrastructure in the Lower Mainland depends on expropriation of private property. Practitioners should have a basic understanding of the process to answer typical questions clients ask when faced with the loss of property rights.
|Equitable Classification and Exemption
A hallmark of the assessment and taxation of property in B.C. is the principle of equity: taxing authorities must deal even-handedly with all taxpayers in a municipality or rural area, and all taxpayers within a class must be treated in the same way. That is, properties with identifiable, similar attributes within a class should be assessed for taxation, e.g., classified, valued and subject to exemptions from assessment and taxation consistently, within a municipality or rural area.
|British Columbia Update
An overview of key legislative changes and legal developments relating to property tax in British Columbia in 2007, prepared for the National Valuation and Legal Symposium Cross-Canada Legal Panel.
|“British Columbia Legal Update”
A brief overview of topical issues relating to British Columbia property assessment and taxation, including the parking site tax, prepared for the Canadian Property Tax Association Western Chapter 2006 Education Seminar Legal Panel.
|British Columbia Legal Update Prepared for the 39th Annual Canadian Property Tax Association National Workshop Cross-Canada Legal Panel
An overview of legislative changes and caselaw developments in British Columbia property assessment and taxation in the past year. The review is not intended to be exhaustive, but instead to provide a cross-section of topical cases which may be of interest both to the B.C. chapter and the national membership. The focus lies on stated case decisions.
|Introduction of ULC Legislation in Alberta
The Business Corporations Act (Alberta) has been amended to provide for the establishment of unlimited liability corporations (ULCs), which have been used for cross-border tax planning for a number of years. Lawson Lundell has extensive experience in structuring transactions that utilize ULCs.