Allan Lanthier

Taxation

Allan Lanthier, FCPA, FCA

Allan Lanthier, a retired partner of an international accounting firm, has been an adviser to both the Department of Finance and the Canada Revenue Agency.

Recent Blog Posts By Allan Lanthier

Court allows Canada-US tax treaty credit against investment tax

Allan Lanthier examines the recent Bruyea decision of the US Court of Federal Claims, which allowed a tax treaty credit against US tax on investment income

DAC Investment and the GAAR: Did the Tax Court of Canada get it right?

Allan Lanthier is unconvinced by the reasoning in a recent Tax Court of Canada decision involving a Canadian-controlled private corporation and the BVI

Crystallizing capital gains before June 25: What about the GAAR?

Allan Lanthier explains why the General Anti-Avoidance Rule, as amended by Bill C-59, should not apply to a planning alternative to new capital gains rules

The new game in town: Capital gains and the alternative minimum tax

The federal government's new capital gains rules have left taxpayers in a pickle says Allan Lanthier. But here's a planning alternative with a deadline of June 24

Deans Knight: The return of the GAAR

The Supreme Court of Canada's decision in Deans Knight is a breath of fresh air and strikes a more appropriate balance, says Allan Lanthier

The Foix decision:  The long and uncertain reach of subsection 84(2)

The broader interpretation by the Federal Court of Appeal in a tax case involving a complex hybrid sale was a breath of fresh air says Allan Lanthier

The United States has rejected the OECD minimum tax. Canada should as well – Part II

Allan Lanthier: The OECD rules were developed by committee after committee and compromise after compromise, and it shows

The United States has rejected the OECD minimum tax. Canada should as well – Part I

Allan Lanthier: We should not hamstring our job creators at the precise time when our giant competitor to the south has rejected the tax

Substantive CCPCs: Is the tax deferral game over?

Allan Lanthier: Ottawa’s new substantive Canadian-controlled private corporation rules should end tax planning that seeks to manipulate non-CCPC status

The federal budget hits private corporations with foreign affiliates

Allan Lanthier: Why Canada’s federal budget included tax measures against CCPCs with CFAs earning foreign accrual property income

The Des Groseillers decision: Charitable donations of stock options

Allan Lanthier: The resolution of a Quebec tax dispute is now in the hands of the Supreme Court, which has recently been taxpayer-friendly

The OECD corporate minimum tax: a disaster in the making

Allan Lanthier says it's time for accounting firms, bodies and industry groups to challenge the flaws in the OECD global corporate minimum tax plan

The Robillard decision:  The uncertain world of death and taxes

Allan Lanthier on confusion in surplus stripping and the post-mortem pipeline, due to a recent Tax Court of Canada decision

The latest Canadian tax scam has a Caribbean flavour

Allan Lanthier looks at the BVI Switch tax avoidance scheme used by wealthy Canadians and what action could be taken by the federal finance minister

Alta Energy: Has the GAAR become toothless? – Part II

In part two of his two-part series, Allan Lanthier highlights areas of the Supreme Court's Alta Energy decision that are open to vigorous debate

Alta Energy: Has the GAAR become toothless? – Part I

In part one of a two-part series, Allan Lanthier looks at the details of the Alta Energy tax avoidance decision by the Supreme Court of Canada

Will the OECD eliminate corporate tax avoidance? We’ll see

Allan Lanthier analyzes the most sweeping overhaul of global tax rules in more than a century

The general anti-avoidance rule and family surplus strips

Allan Lanthier on why the Deans Knight court decision should cause HNW individuals to pause before engaging in aggressive surplus stripping through intergenerational wealth transfers

Tax relief for family business transfers: A legislative fiasco – Part II

In part two of a two-part series, Allan Lanthier outlines the strategy for legislative repeal and predicts what lies ahead for Bill C-208

Tax relief for family business transfers: A legislative fiasco – Part I

Bill C-208 has handed tax avoiders a new surplus stripping scheme on a silver platter explains tax expert Allan Lanthier in a two-part series

Tooth or Consequences: The Perils of Online Tax Filing

Allan Lanthier explains a recent case in the UK Supreme Court, HMRC v Tooth, and its consequences in a Canadian context

The myth of CERB forgiveness

Critics of CERB forgiveness miss the point, says Allan Lanthier, FCPA, FCA

Canada should repeal the small business deduction

There is little evidence supporting the efficacy of the SBD, says Allan Lanthier

Ottawa should forget about limiting interest expense deductibility

Allan Lanthier on the OECD's proposal to limit excessive debt leveraging

Let’s bring some common sense to the estate freeze debate

Allan Lanthier, FCPA, FCA, responds to recent estate freeze critiques