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Tuesday, January 30, 2018 @ 9:20 AM

How to know who’s legally on the hook for tax return errors tax_blame_sm

For most people, preparing a tax return ranks only slightly above getting a root canal on the enjoyment scale. Many seek to avoid — or at least minimize — this suffering by engaging an accountant to prepare their tax returns. Those that do may reasonably question to what extent they are responsible for spotting errors or omissions in their returns. ... [read more]

Monday, January 29, 2018 @ 9:40 AM

Financial implications a consideration when deciding U.S. status green_card_sm

Lawful permanent residents should only decide to maintain status, abandon their green cards or apply for U.S. citizenship with the knowledge of how this can affect them. Understanding the implications of these actions before they are taken could save tax or tuition dollars, ensure continued ability to live in a desired location, and prevent legal proceedings. ... [read more]

Friday, January 26, 2018 @ 8:43 AM

Litigation beyond Tax Court: Injunctions, appeals and mandamus orders

The Tax Court has two procedural veins, general and informal, and the Federal Court of Appeal’s (FCA) ability to hear an appeal is constrained by the procedure chosen. Specifically, an appeal lies to the FCA from informal procedure at Tax Court only on the limited grounds set out in s. 27(1.3) of the Federal Courts Act. Some of the grounds are quite specific, such as basing a decision on an erroneous finding of fact that it made in a perverse or capricious manner while other grounds are broader, such as failure to observe a principle of natural justice or procedural fairness. ... [read more]

Thursday, January 25, 2018 @ 1:14 PM

Judge appointed in British Columbia

The regional director general and senior general counsel with Justice Canada, Jasvinder S. (Bill) Basran, has been named as a judge with the Supreme Court of British Columbia in Vancouver. ... [read more]

Wednesday, January 24, 2018 @ 8:25 AM

Valuation of IP based on a royalty stream

Challenges arise in the valuation of intellectual property (IP) due to a number of factors, including: difficulties in estimation of cash flows to be generated from the IP’s use or licensing, particularly for early-stage or disruptive IP; tax considerations due to the ease of migration of IP; and selection of an appropriate discount rate and the quantification of risk. ... [read more]

Monday, January 22, 2018 @ 12:37 PM

Tax Views: The OECD's reaction to international tax planning | Vern Krishna

As in Newtonian physics, actions in tax law attract reactions. As global trade expands, so do the problems of monitoring the taxation of multinational enterprises (MNEs). Countries are eager to claim taxing jurisdiction over foreign corporations that operate within their borders as they provide revenues and cannot generate the political emotion that domestic persons muster. ... [read more]

Monday, January 22, 2018 @ 11:06 AM

Revenue Quebec can issue demand letters to third parties outside province, Appeal Court rules

The Quebec Court of Appeal has ruled the province’s tax authority can issue demand letters and request the disclosure of financial information from third parties outside the province to determine whether a taxpayer is subject to the province’s tax laws. ... [read more]

Thursday, January 18, 2018 @ 1:16 PM

New leaders and partners at Borden Ladner Gervais

Personnel changes at Borden Ladner Gervais LLP (BLG) mean that there are now 19 new partners at the firm and new leaders of one of the firm’s working groups. ... [read more]

Thursday, January 18, 2018 @ 9:43 AM

Tax litigation beyond the Tax Court: Federal Court and superior provincial courts

The Federal Court of Appeal in Ereiser v. Canada 2013 FCA 20 concluded that the Tax Court does not have civil jurisdiction. ... [read more]

Wednesday, January 17, 2018 @ 12:47 PM

Stikeman Elliott adds seven partners

Stikeman Elliott LLP has new partners in Montreal, Toronto and Calgary. ... [read more]