Canadian Tax Adviser

The latest tax news and analysis from KPMG's Tax practice in Canada

Canadian Tax Adviser

February 2010

• Creditor-Proofing Asset Rollover Fails Again
• Employer-Provided Scholarship Programs
• Courts and the CRA Confirm NPOs Cannot Operate For Profit
• Quebec Increases Investment Tax Credit on M&P Equipment
• No Change to the CRA’s 1 Percent Prescribed Rate in Q1 of 2010
• Ontario Corporate Tax Rate Cuts and HST Measures Now Law
• Stay Up-to-Date with KPMG Webcasts

November 2009

• Employers May Have to Pay More GST on Pension Plan Expenses
• Canadian AcSB Finalizes Private Enterprises GAAP
• Some Employer-Provided Scholarships Still a Taxable Benefit
• CRA Prescribed Rates Stay Down for Fourth Quarter
• Heron Bay — Moneylender Denied Bad Debt Write-Off

October 2009

• Independent Power Producers — Plan to Optimize Green Tax Benefits
• CRA Clarifies "Business Continuity Test" in Partnership Wind-Up
• Functional Currency Elections — Treatment of Partnership Income
• Low Down on CRA Prescribed Rates for the Third Quarter of 2009
• Ontario WSIB Announces Premium Rates for 2010
• Tax Planning for You and Your Family 2010 — Special Client Offer

August 2009

• 2009 Auditor General's Reports Released
• CRA Tweaks Taxation of Employee Benefits
• CRA Accepts "Old Form" SR&ED Claims For an Additional Year
• Low Down on CRA Prescribed Rates for the Third Quarter of 2009
• CRA Still Paying Municipalities' Tax Refunds Where T2 Not Filed
• Ontario HST — No ITC Restrictions on Goods and Services for Re-supply

June 2009

• Federal Budgets' CCA Changes Now Substantively Enacted
• Landrus - FCA Agrees GAAR Doesn't Apply to Deny Partnership Terminal Loss
• New Proposals for IFRS Income Tax Accounting Standard Released
• Canadian Board Seeks Input on Proposed Accounting Standards for Private Enterprises

May 2009

• Tax Litigation — Take a Strategic Approach
• Ontario PST-GST Harmonization Memorandum of Agreement
• Quebec Plans QST Increase — Make Big Ticket Purchases Before 2011
• SIFT Normal Growth Guidelines Tweaked

April 2009

• CRA's Post — Lipson GAAR Position -Status Quo?
• 2008 and 2009 Federal Budget Measures Now Enacted
• Leola Purdy, Sons Ltd. — TCC Allows Taxpayer to Correct Capital Loss Filed to Income Loss
• Demand Obligations — Amendments to Ontario's Limitations Act Overturn Hare Decision
• Tembec, Cascades, Provigo — SCC Denies Taxpayers' Convertible Debentures Appeal

March 2009

• Prescribed Rates Drop — Consider Income Splitting
• GAAR Update — Latest CRA Stats
• CRA Comments on R&D Benefits Available to Joint Venture Members
• B.C. Court Says "Creditor-Proof" Rollover Results in Fraudulent Conveyance
• CRA Provides Transitional Guidance on Filing SR&ED Claims on Form T661

January 2009

• Employee Stock Options, Share Valuation Discussed at 2007 CTF Conference Round Table
• CRA Reviews Position on Index-Linked Debt Obligations
• CRA Says Income Tax Refunds Cannot Be Assigned
• Saskatchewan Reintroduces Mineral Exploration Tax Credit

December 2008

• Ontario Harmonization — Ordering of Tax Credit Claims
• 489599 B.C. — Court Expands Meaning of "More Than Five Full-Time Employees"
• Joint Tax Committee Responds to Draft SIFT Legislation
• AMT Fix Recommended For Unit Trusts
• Ontario's Tax "Exemption" For Commercializing Intellectual Property
• IBM Canada Ltd. — Ontario EHT Applies on Expatriates' Pay — SCC Denies Appeal

October 2008

• Hasiuk — Indirect Payments — Anti-Avoidance Rule's Double Whammy
• Chartier and Nadeau — TCC Holds Options Do Not Upset Corporation's QSBC Status
• Sentinel Hill — WHT Gross-Up Clause Traps Taxpayer — End of the Line
• Prescribed Rates Hold the Line for the Fourth Quarter of 2008
• Update on Assessment Process for Ontario M&P Capital Tax Elimination
• Corporate Attribution Rule Derails Estate Freeze Plan

September 2008

• Update on Integration 2008 — Fine Tuning the Engine
• Update — New Rules Deem a Provincial PE For Tax Years Ending After 2008
• Jolly Farmer Products Inc. — CRA Attacks on Taxpayer's Business Judgment Fail
• Redeemer Foundation — Supreme Court Upholds CRA Powers to Access Third-Party Information
• Tax Planning for You and Your Family 2009 — Special Client Offer

August 2008

• Finance Releases Budget 2008 and SIFT Draft Legislation
• Journal Entry Alone Not Payment of Capital Dividend
• Tembec, Cascades, Provigo — FCA Denies Financing Deduction on Convertible Debentures
• Unrelated Employers of Same Apprentice Can Both Claim Tax Credit
• Doing International Business in British Columbia: IFC Regime
• CRA Cannot Piggyback on Quebec Assessment

July 2008

• Ontario Issues Form to Claim New M&P Capital Tax Exemption
• CRA Says Rent Expense Averaging Under GAAP Not Permitted for Tax
• CRA Says CCPC Eligible Dividend Designation Must Quantify Payable Amount
• Moving Allowances and ITCs — Dispute Continues
• Rachfalowski — Golf Club Membership Not a Taxable Benefit
• CRA Releases New Guidelines for Charity Fundraising Activities

June 2008

• SCC Upholds CRA's Broad Powers to Obtain Third Party Information
• Ontario/Federal Corporate Income Tax Harmonization — Changes to Filing Practices
• Hartrell — Court Finds Taxpayer a De Facto Director
• Dimaria — Tax Treatment of Scholarship Paid to Employee’s Child
• Federal and Provincial Corporate Tax Rates at a Glance

April 2008

• MacKay — FCA Applies GAAR To Deny Partnership Losses
• Ontario Issues Guidance on Retroactive Capital Tax Cuts
• CRA Confirms No Late Designations for Eligible Dividends
• Canadian Corporations Must File U.S. Tax Returns on Time to Claim Deductions
• Canco's R&D Tax Credits Not Reduced by Associated Non-residents
• Ontario WSIB to Overhaul Employers’ Rebate Program

March 2008

• GAAR Committee Stats — CRA Winning Two out of Three Times
• Joint Committee Recommends Rollover Treatment for SIFT Conversions
• CRA Updates Administrative Policies on Amalgamations
• Government Hears KPMG Recommendations at SR&ED Meeting
• Ontario "Mini-budget" Cuts Capital Tax Rates for 2007
• CRA Provides Welcome Clarification of CCPCs' "GRIP Addition For 2006"

January 2008

• 2007 Budget and Mini-Budget Tax Cuts are Now Law
• SR&ED Program Should be More Relevant and Accessible — KPMG Survey
• Ontario-Federal Corporate Tax Harmonization — Transition of Responsibilities to CRA
• New CRA View on Interest Deductibility on Line of Credit
• Ontario Corporate Minimum Tax Fix for Rising Canadian Dollar
• WSIB Offers Amnesty for Unregistered Ontario Employers

October/November 2007

• Tembec — TCC Determines Principal Amount of Convertible Debentures
• Managing the Transition to IFRS
• Waiving Ontario R&D Credit May Enhance Tax Savings
• Alberta Large Corporations Must Now File Provincial Notice of Objection
• SLM Direct Marketing — TCC Finds Agency Relationship

August/September 2007

• Y.S.I.’s Yacht Sales — TCC Clarifies "Recipient" of Supplies
• Administrative Relief for 2006 Eligible Dividend Filings
• Ontario Corporate Minimum Tax — New Regs for Reorgs
• Ontario-Federal Corporate Tax Harmonization Bill Includes R&D Provisions
• Finance Announces "Fix" for Income Trusts' T3 Reporting
• Tax Planning for You and Your Family 2008 — Special Client Offer

July 2007

• Quebec Provides Details on Parallel Tax System for Income Trusts
• Don't Forget Federal Apprenticeship Job Creation Tax Credit
• Nova Scotia ULCs Try to Become More Like Alberta ULCs
• Cloverdale — Taxpayer is Allowed Doubtful Accounts Reserve Against Related Party Debt
• CRA Confirms CCA Classifications of Printers
• Make Sure You’ve Got Your Supplier’s Number

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