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TaxMatters@EY – November 2009

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In the latest issue of our monthly look at tax news and developments, we share our perspectives on the following:

  • Swiss Bank UBS’s release of account-holder information to the US Internal Revenue Service — and its implications for Canadians with offshore bank accounts who may not be reporting all their worldwide income
  • Scholarships to employees' family members: a change in CRA policy
  • The results of Ernst & Young's 2009 global transfer pricing survey
  • Yet another prominent case in which the Tax Court of Canada has upheld the CRA’s challenge of a Barbados spousal trust

You’ll find all this — plus our latest tax publications, articles and alerts — in the latest issue of TaxMatters@EY.


CRA tackles offshore investments
Gena Katz, Toronto

In September, Canada Revenue Agency (CRA) officials met with representatives from Swiss bank UBS in an attempt to gain information about Canadian account holders who may not be reporting foreign investment information to the Canadian tax authorities. The visit followed on the heels of the US Internal Revenue Service’s success in forcing UBS to provide account holder detail for thousands of US clients who were suspected tax evaders.

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Scholarships to employees' family members: a change in CRA policy
Jennifer Chivers-Wilson and Greg MacKenzie, Kitchener

Educational institutions often provide educational benefits to their employees' family members in the form of tuition waivers, scholarships and bursaries. Other employers may also provide scholarship funds to children of employees.

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Ernst & Young’s 2009 global transfer pricing survey: authorities respond to a changing world

The credit crunch, a worldwide recession and turmoil in the financial markets have brought serious, and often unforeseen, challenges to multinational enterprises in managing their transfer pricing. These same factors are also challenging governments and influencing their fiscal approaches. Budget deficits, stimulus packages and bailouts all have significant costs.

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Poor implementation and the GAAR undo another Barbados spousal trust: Antle et al v the Queen, 2009 TCC 465
Mike Walker, London

This is the second recent Tax Court decision involving a successful challenge by the Canada Revenue Agency of the use of a Barbados spousal trust claiming treaty exemption on a capital gain.

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Publications, articles and presentations

Bullet View the list of featured publications below or see our full list of our 2008-2009 Tax Alerts.

 

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