Publications
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Use of “private” mutual fund trusts for employee’ investments through an RRSP
An increasing number of employers are looking at the possibility of creating investment vehicles to allow their employees to make investments in the employer corporation or a portfolio managed by the employer that will qualify for inclusion in, inter alia, registered retirement savings plans (RRSP), (…)
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Loss of the capital gain exemption related to the disposition of qualified small business corporation shares: beware of the options for acquiring shares
A recent decision of the Tax Court of Canada in the case of Line Durocher c. Sa Majesté La Reine1 illustrates the dangers of granting a simple option for acquiring shares in the specific context of the implementation of a shareholder agreement in respect of the Canadian-controlled private (…)
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Proposed changes to tax rules on stock options
The election of a majority Liberal government last October 19 signaled that there would be numerous changes to Canadian tax policy, particularly for individuals. One of these changes which has made waves in the business community is the reform of the tax regime applicable to stock options. Under (…)
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Major changes enable registered charitable organizations to invest in limited partnership units
The federal budget presented on April 21, 2015 (the “Budget”) contains important measures enabling registered charitable organizations and private and public foundations (hereinafter collectively referred to as “Registered Organizations”) to invest their funds in units of a limited partnership. (…)
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FATCA for investment funds – Be ready for May 1, 2015!
The Foreign Account Tax Compliance Act, or FATCA, has been an integral part of Canada’s tax system for over a year. Originally legislated under U.S. law, FATCA allowed the Internal Revenue Service (“IRS”) to obtain information from financial institutions about the financial accounts of U.S. citizens (…)
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Rules on mark-to-market properties — A pitfall to avoid
The Income Tax Act (Canada) contains specific rules which apply to certain properties held by financial institutions known as the mark-to-market properties rules (hereinafter “MTMP”). These complex rules are often poorly understood and can result in unexpected tax consequences in various situations (…)
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Quarterly legal newsletter intended for accounting, management, and finance professionals, Number 23
CONTENTS The 2014 Federal Budget Plan sounds the death knell for two family tax planning measures much appreciated by entrepreneurs and some professionals The Expert and the Court You signed a contract for services... with an employee? How to properly identify the relationship between the (…)
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Quarterly legal newsletter intended for accounting, management, and finance professionals, Number 19
CONTENTS Part XII.2 Tax Applicable to Trusts: a Potentially Expensive Tax Whichis Often Overlooked Application of the Anti-avoidance Rule in Subsection 83(2.1): Caution Is Required in the Context of the Acquisition of a Private Corporation Revenu Québec to Scrutinize Trusts Directors’ (…)
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Quarterly legal newsletter intended for accounting, management, and finance professionals, Number 17
The Application for Rectification by the Court Is Not a Cure for all Ills: Prevention is Better than (Attempting!) a Cure Register your Trade-marks! The Importance of Having a Detailed Power of Attorney in the Event of a Person’s Incapacity Effect of a Unanimous (…)
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Quarterly legal newsletter intended for accounting, management, and finance professionals, Number 16
The Trust : An Efficient Asset Protection Tool? Amendments to the Obligations of Employers Hiring Foreign Workers – One Year Later: Are you Ready for Service Canada’s Verification? Did you Know? Trustee’s Tax Liability
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Quarterly legal newsletter intended for accounting, management, and finance professionals, Number 14
Defined Benefit Pension Plans : The Temporary Funding Relief Measures will Likely be Extended! A New Statutory Framework for Federal Not-for-profit Organizations Conversion of Debt into Shares by a Corporation in Financial Difficulty; Pay Attention to the Tax Consequences Conflicting (…)