Tax: M&A, Reorganizations and Restructuring Transactions

CRA releases new guidelines for GST voluntary disclosures

On December 13, 2017, the Canada Revenue Agency released a revised update of its memorandum on the GST/HST voluntary disclosure program.

Government of Canada tests the limits under the Income Tax Act in 2017

In 2017, the Canada Revenue Agency (the CRA) pursued litigation which tested the limits of its powers under the Income Tax Act.

Canadian government eliminates facilitation payments exclusion in the Corruption of Foreign Public Officials Act

As of October 31, 2017, facilitation payments will no longer be excluded from the bribery offence under Canada’s Corruption of Foreign Public...

Federal Court of Appeal’s Univar decision provides guidance on how to apply the GAAR

On October 13, 2017, the Federal Court of Appeal released its highly anticipated decision in Univar, finding that the General Anti-Avoidance Rule...

Proposed Draft Legislation for Investment Limited Partnerships

The Department of Finance released draft legislation to amend the Excise Tax Act (Canada), which will likely have a significant impact on private...

Canada publishes bail-in regulations

On June 16, 2017, the Canadian federal government published its draft bail-in regulations for public comment. This Update offers a detailed overview...

Canada signs multilateral tax agreement

Canada and 67 other jurisdictions signed the OECD’s multilateral tax convention (referred to as the multilateral instrument or “MLI”) on...

Saskatchewan’s 2017-18 budget: Provincial Sales Tax changes

On March 23, 2017, Saskatchewan’s government released its 2017-2018 budget (the Budget). Included in the Budget were some significant changes to...

New world for leveraged U.S. real estate partnerships

For Canadian entities seeking to access the booming U.S. real estate market or to diversify their global real estate holdings, strategically...

Federal Court of Appeal denies CRA routine access to tax accrual working papers

The Federal Court of Appeal's decision in BP Canada Energy Company v. MNR (2017 FCA 61) deals with whether the Minister of National Revenue could...