Tax Alert – Canada

Tax Alert – Canada

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Tax Alerts cover significant tax news, developments and changes in legislation that affect Canadian businesses.

Highlights from the CRA’s 2013-14 APA Program Report
No. 40, 14 July 2014

On 14 July 2014, the Canada Revenue Agency released its Advance Pricing Arrangement (APA) Program Report for the fiscal year ending 31 March 2014. Learn more in our latest Tax Alert.

Ontario budget 2014–15
No. 39, 14 July 2014

Ontario Finance Minister Charles Sousa tabled the province’s post-election fiscal 2014–15 budget on 14 July 2014.

Revised Form T1135: CRA announces permanent relief for 2014 and later years
No. 38, 10 July 2014

On 8 July 2014, the Canada Revenue Agency (CRA) released a revised Form T1135, Foreign Income Verification Statement, for Canadians required to report specified foreign property with a total cost of over $100,000 for 2014 and later taxation years. Among the changes included in the new version, further summarized below, the CRA essentially adopts on a permanent basis a streamlined reporting method similar to the transitional reporting method introduced for 2013, and eliminates the T3/T5 reporting exception.

Decision released in Marzen Aluminum transfer pricing case
No. 37, 19 June 2014

On 10 June 2014, the Tax Court of Canada released its judgment in Marzen Artistic Aluminum Ltd. v The Queen. The case has several important implications for transfer pricing in Canada and adds to the growing body of Canadian transfer pricing jurisprudence.

CRA MAP report reflects continued improvement of timelines and high volume of Canada-initiated cases
No. 36, 12 June 2014

On 9 June 2014, the Canada Revenue Agency (CRA) released its Mutual Agreement Procedure (MAP) Program Report for the fiscal year ending 31 March 2014.

CRA issues revised memorandum on contemporaneous documentation
No. 35, 5 June 2014

On 28 March 2014, the Canada Revenue Agency (CRA) issued a revised Transfer Pricing Memorandum, Requests for Contemporaneous Documentation, replacing the previous memorandum on this topic it issued in 2004 and clarifying several issues.

Quebec budget 2014-15
No. 34, 4 June 2014

Quebec Minister of Finance Carlos J. Leitão tabled the new government’s fiscal 2014-15 budget on 4 June 2014.

Nunavut budget 2014-15
No. 33, 26 May 2014

Finance Minister Keith Peterson tabled Nunvaut’s fiscal 2014–15 budget on 26 May 2014.

Ontario budget 2014-15
No. 32, 1 May 2014

Finance Minister Charles Sousa tabled Ontario's fiscal 2014–15 budget on 1 May 2014.

Lehigh Cement: FCA interprets 95(6)(b) as a status manipulation rule
No. 31, 25 April 2014

On 23 April 2014, the Federal Court of Appeal (FCA) released its much-anticipated decision and reasons in The Queen v Lehigh Cement Limited et al. The decision upheld the Tax Court of Canada’s decision, which had allowed the taxpayers’ appeals, but for very different reasons.