Taxation
Thought Leaders
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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Thought Leaders
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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Thought Leaders
The Canadian Taxpayers Federation’s politics are anti-Indigenous — so why do media outlets still quote them?
Canadian journalists should be wary of groups like the CTF, says Sociology Professor Kyle Willmott
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Management
Using losses in a corporate group: An overview of loss consolidation
Brian Nichols and Kelsey Horning of GSNH on loss consolidation arrangements
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Profession
Sunday News Roundup 21.12.12: Fiscal anchors, full of beans, Alta opinions, and more
Wrapping up the odds and ends in this week’s Canadian accounting news
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Practice
Tax Court rules that gift of shares of a private corporation to a foundation was ineligible for a charitable tax credit
Tax lawyer and accountant David J Rotfleisch on gifting non-qualifying securities such as a promissory note to a registered charity
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Thought Leaders
CRA applying GAAR for outside/inside ACB misalignment on 55(3)(a) transactions
In the final part of a three-part series, Doug S. Ewens and Kenneth Keung of Moodys Tax Law ask whether the CRA is over-reaching on the scope of the GAAR
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Thought Leaders
Our response to the CRA's position on creditor-proofing reorganizations – part 2 (a case study)
A three-part series from Doug S. Ewens and Kenneth Keung of Moodys Tax Law
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Practice
What can a taxpayer do if a CRA decision letter is unclear?
Canadian accountant and tax lawyer David J Rotfleisch on a recent Federal Court decision against Canada Revenue Agency
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Practice
When to file (and when not to file) a service complaint against the CRA
Pierre Alary of Gowling WLG on factors that support the filing of a service complaint as part of an ongoing tax dispute
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Practice
Pandora Papers: More smoke than fire? CRA VDP operations manual: Top 10 takeaways
Stevan Novoselac and John A. Sorensen of Gowling WLG on the nuances of the CRA's VDP Operations Manual
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Practice
Rectification and the vanishing prospects for common sense and compassion
John Sorenson of Gowling WLG asks whether the Glenmac decision demonstrates a tax system that is just, equitable and fair
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