Stephen J. Fyfe

CRA Reaffirms Position on Activities Carried On Outside the Municipality
Stephen J. Fyfe,Stephanie A. Wong, December 15, 2011
A recently released CRA technical interpretation provides municipal electricity utilities (MEUs) and other municipally-owned corporations (MOCs) with continuing reassurance regarding the CRA’s application of the geographic source of income test in paragraphs 149(1)(d.5) and 149(1)(d.6) of the...

Finance Eliminates Tax Advantages of Stapled Security Transactions
Richard Bennett,Stephen J. Fyfe,Stephanie A. Wong, July 22, 2011
On July 20, 2011, the Department of Finance Canada (Finance) announced proposed amendments intended to eliminate the tax advantages of stapled security transactions. The Press Release and accompanying Backgrounder can be viewed on Finance’s website. Draft legislation has not yet been released.

Public Company Spin-Off Transactions
Stephen J. Fyfe,Kim McGarrity,Stephanie A. Wong, June 6, 2011
Corporate spin-off transactions have again become a preferred structure for companies to release shareholder value and achieve other business purposes. In a spin-off, the parent corporation (Pubco) divides the assets and liabilities of the firm and chooses the capital structure for the new...