martindale.com
Legal Library
|
Borden Ladner Gervais LLP Calgary, AB Document Search Results (9) Sort by:  | Primer on Transfer Pricing Audits
Patrick L. Lindsay, Salvatore Mirandola, Stephanie A. Wong; Borden Ladner Gervais LLP;
Legal Alert/Article March 14, 2012, previously published on March 2012 Transfer pricing attracts a lot of attention from tax authorities, generally because large amounts are often involved and most countries are concerned with protecting their own tax base. Transfer pricing refers to the manner in which prices for goods and services are determined among entities...
| | Two for Two to Rectify: The McPeake Case
Patrick L. Lindsay, Salvatore Mirandola; Borden Ladner Gervais LLP;
Legal Alert/Article February 23, 2012, previously published on February 2012 Rectification has emerged as an important remedy for certain taxpayers faced with unintended tax consequences from transactions in which they participate. If certain conditions are met, the remedy allows taxpayers essentially to ‘fix’ the transaction documents (or even the...
| | Latest Step in CRA’s New Audit Approach: “Risk Assessment” Interviews with Large Businesses
Patrick L. Lindsay, Salvatore Mirandola; Borden Ladner Gervais LLP;
Legal Alert/Article February 14, 2012, previously published on February 2012 In the next few weeks, the Canada Revenue Agency (“CRA”) plans to conduct individual risk-assessment interviews with a select group of 50 large businesses. These taxpayers face the prospect of being labelled “high-risk,” a designation that will likely come with significant...
| | Implications of Copthorne on Tax Planning
Patrick L. Lindsay, Stephanie A. Wong; Borden Ladner Gervais LLP;
Legal Alert/Article December 27, 2011, previously published on December 2011 In Copthorne, the Supreme Court of Canada (“SCC”) addressed anticipatory tax planning under the general-anti avoidance rule (“GAAR”). In this case, an additional step was added to a transaction that prevented paid-up capital (“PUC”) from being eliminated. A year...
| | Omers Energy Inc. v. Alberta (Energy Resources Conservation Board)
Oliver Jull, Michael A. Marion; Borden Ladner Gervais LLP;
Legal Alert/Article October 17, 2011, previously published on October 2011 Omers Energy Inc. v. Alberta (Energy Resources Conservation Board): Alberta Court of Appeal interprets “capable of producing” to mean “presently capable of producing in meaningful quantities”.
| | Investments in a Registered Plan - A Trap for the Unwary
Richard Eisenbraun; Borden Ladner Gervais LLP;
Legal Alert/Article August 17, 2011, previously published on August 2011 The June, 2011 Canadian Federal Budget (the Budget) proposes to introduce certain rules under the Income Tax Act (Canada) relating to registered retirement savings plans (RRSPs) and registered retirement income funds (RRIFs) (collectively, Registered Plans) that previously applied only to tax-free...
| | Limited Partnerships
Ross D. Freeman; Borden Ladner Gervais LLP;
Legal Alert/Article July 6, 2011, previously published on June 2011 Very few investment structures permit investors to claim tax deductions associated with their investment. One of these investments, flow-through shares, was discussed in an earlier edition of this feature. In this issue, we consider investments in limited partnerships. Unlike flow-through shares,...
| | GST/HST Returns: Are You Ready For June 30?
Beverly J. Gilbert, Camille Kam; Borden Ladner Gervais LLP;
Legal Alert/Article June 28, 2011, previously published on June 2011 The June 30, 2011 deadline for the filing of the first round of GST/HST 494 returns is quickly approaching. Highlighted below are some of the things pension plan trustees, pension plan sponsors and administrators should keep in mind to assist them with their new HST compliance obligations.
| | Public Company Dividends
Ross D. Freeman; Borden Ladner Gervais LLP;
Legal Alert/Article June 6, 2011, previously published on May 2011 Canadians who are approaching or have reached retirement age often look for yield investments that can pay a monthly or quarterly cash distribution to provide them with enough cash to live on without having to continually sell a portion of their investments. In previous months, we looked at some of...
|
|