Tax Tax

Supreme Court releases Alta Energy decision: taxpayer wins, application of GAAR to tax treaties clarified

Earlier today, the Supreme Court of Canada released its decision in Canada v. Alta Energy Luxembourg S.A.R.L., 2021 SCC 49.

136 countries agree to OECD/G20 Inclusive Framework’s two-pillar solution to international tax reform

Last week, 136 countries, including Canada and the United States, announced that they have agreed to the OECD/G20 Inclusive Framework’s two-pillar...

A discordant jurisprudence: what does it mean to be ‘Acting in Concert’?

Under the Income Tax Act (Canada) taxpayers are deemed to not deal at arm’s length if they are “related”. In all other circumstances, taxpayers...

The Canadian federal interest withholding tax regime

Most payments of interest made by Canadian borrowers to arm’s length non-Canadian lenders do not attract Canadian federal withholding tax, while...

New CRA guidance on input tax credit allocation methods for financial institutions under section 141.02 of the Excise Tax Act

The Canada Revenue Agency recently released new guidance on #inputtaxcredit allocation methods for #financial institutions. In their Osler Update,...

OECD/G20 Inclusive Framework reaches high-level agreement on two-pillar approach to international tax reform

In their Osler Update, authors Patrick Marley, Peter Macdonald, Kaitlin Gray and Taylor Cao comment on the statement by the OECD/G20 Inclusive...

Exchangeable share structures – an overview

Exchangeable share structures have been a fixture in structuring cross-border share exchange mergers and acquisitions involving Canadian corporations...