Tax Alert – Canada
Tax Alerts cover significant tax news, developments and changes in legislation that affect Canadian businesses.
Manitoba and Alberta budgets 2014–15
Nos. 19 and 20, 7 March 2014
GST/HST election for closely related persons
No. 18, 5 March 2014
The 2014 federal budget proposes a number of changes to the “nil consideration” election that is currently available to relieve the GST/HST that would otherwise apply to certain transactions between members of a closely related group. Subject to one exception noted in this alert, these changes will take effect for elections made on or after 1 January 2015 and will apply to supplies made between parties to such an election on or after that date. Learn more in our latest Tax Alert.
Revised Form T1135: CRA announces new transitional relief for 2013
No. 17, 27 February 2014
On 26 February 2014, the Canada Revenue Agency (CRA) announced new transitional relief for Canadians who must comply with more detailed Form T1135 information reporting requirements for foreign property with a cost of over $100,000. The transitional relief, which applies only for the 2013 taxation year, is intended to assist taxpayers in transitioning to the more onerous reporting requirements, and responds to concerns raised by taxpayers and various stakeholders. Learn more in our latest Tax Alert.
Related party R&D/design costs dutiable in Canada: Skechers USA Canada Inc. v The President of the CBSA
No. 16, 26 February 2014
In one of the most important customs cases in years, the Canadian International Trade Tribunal has just confirmed an aggressive interpretation by the Canada Border Services Agency (CBSA) concerning additions to the transaction value for inter-company payments outside of the invoice amount or transfer price relating to design and development costs allocated to the importer. Learn more in our latest Tax Alert.
Federal budget introduces new international tax measures
No. 15, 24 February 2014
The federal budget tabled on 11 February 2014 includes a number of measures targeting specific elements of Canada’s international tax system including insurance, offshore regulated banks, back-to-back loans and immigration trusts. The budget also announces new public consultations on a broader range of international tax issues, and confirms the government’s intention to proceed with certain previously announced reforms. Learn more in our latest Tax Alert.
OECD releases standard on automatic exchange of financial account information
No. 14, 21 February 2014
On 13 February 2014, the Organisation for Economic Cooperation and Development (OECD) released a model Competent Authority Agreement and Common Reporting Standard (CRS) designed to create a global standard for the automatic exchange of financial account information. The CRS represents another global compliance burden for financial institutions and increases the risks and costs of serving globally mobile wealthy customers. Learn more in our latest Tax Alert.
Quebec budget 2014-15
No. 13, 20 February 2014
Quebec Minister of Finance and the Economy Nicolas Marceau tabled the province’s fiscal 2014-15 budget on 20 February 2014. Learn more in our latest Tax Alert.
British Columbia budget 2014-15
No. 12, 18 February 2014
BC Finance Minister Michael de Jong tabled the province’s fiscal 2014-15 budget on 18 February 2014. Learn more in our latest Tax Alert.
Invoices of accommodation: important Tax Court of Canada decision in Salaison Lévesque Inc.
No. 11, 13 February 2014
On 4 February 2014, the Tax Court of Canada rendered a key decision in Salaison Lévesque Inc. on whether the Quebec Revenue Agency was correct in refusing the taxpayer's claim for input tax credits in respect of GST paid to certain placement agencies that had not remitted the GST to the tax authorities. Learn more in our latest Tax Alert.
Federal budget 2014–15
No. 10, 11 February 2014
Read our analysis of the 2014 federal budget, tabled on 11 February in the House of Commons by Finance Minister Jim Flaherty.
Canada and the US sign intergovernmental agreement to implement FATCA
No. 09, 10 February 2014
On 5 February 2014, Canadian Finance Minister Jim Flaherty announced that Canada has signed an intergovernmental agreement (IGA) with the US regarding the enhanced exchange of tax information in connection with the Foreign Account Tax Compliance Act (FATCA). The Department of Finance also released legislative proposals to implement the IGA under Canadian law, related explanatory notes and a selection of FAQs with responses.
Northwest Territories budget 2013–14
No. 08, 7 February 2014
Finance Minister Michael Miltenberger tabled the Northwest Territories’ fiscal 2014–15 budget on 6 February 2014.
New Brunswick budget 2014–15
No. 07, 5 February 2014
Finance Minister Blaine Higgs tabled New Brunswick's fiscal 2014–15 budget on 4 February 2014.
OECD releases draft country-by-country reporting template for comment
No. 06, 31 January 2014
On 30 January 2014, the Organisation for Economic Cooperation and Development (OECD) released the much anticipated draft of its proposed template for country-by-country reporting to tax authorities in its Discussion Draft on Transfer Pricing Documentation and CbC Reporting.
Many employers are not properly reporting employee taxable benefits
No. 05, 27 January 2014
Many employees are facing thousands of dollars in back income taxes and interest charges after the Canada Revenue Agency (CRA) found that certain taxable benefits were not properly reported as employment income on the employees’ personal income tax returns. Their employers are also facing penalties and interest for failure to withhold and remit income taxes and the reporting of taxable benefits in their employees’ T-4s.
GST/HST exemption for patient and visitor hospital parking
No. 04, 27 January 2014
On 24 January 2014, the Department of Finance announced that supplies of hospital parking will generally be exempt, whether they are made by the hospital itself, by an affiliated charity such as a foundation or by another public service body. Parking supplied by a charity or other public service body in any other circumstances will generally be taxable.
Details released on Canada’s new Offshore Tax Informant Program
No. 03, 16 January 2014
On 15 January 2014, the CRA released details of its Offshore Tax Informant Program (OTIP). First announced in the 2013 federal budget, the program is intended to allow the CRA to make financial rewards to individuals who provide information related to major international tax non-compliance that leads to the collection of Canadian taxes owing.
CETA’s impact on the mining and energy products sector
No. 02, 9 January 2014
The Comprehensive Economic and Trade Agreement (CETA), agreed to in principle by the executive branches of Canada and the EU in October 2013, will offer new trade and supply chain opportunities for importers, exporters and investors in the mining and energy products sector.
TCC dismisses appeal on transfer pricing reassessment of 2003 factoring transactions
No. 01, 7 January 2014
On 28 December 2013, the Tax Court of Canada (TCC) made public its 13 December judgment in McKesson Canada Corporation v The Queen.