Allan Lanthier
Taxation
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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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The myth of CERB forgiveness
Critics of CERB forgiveness miss the point, says Allan Lanthier, FCPA, FCA
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Canada should repeal the small business deduction
There is little evidence supporting the efficacy of the SBD, says Allan Lanthier
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Ottawa should forget about limiting interest expense deductibility
Allan Lanthier on the OECD's proposal to limit excessive debt leveraging
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Let’s bring some common sense to the estate freeze debate
Allan Lanthier, FCPA, FCA, responds to recent estate freeze critiques
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