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HTMLGST/HST Closely Related Entities Election - New Filing Requirements
Douglas Chen, Jesse I. Goldman, John (Jay) A. Winters; Bennett Jones LLP;
Legal Alert/Article
January 23, 2015, previously published on December 18, 2014
If you are planning on adding a closely related GST group election in the new year (CRA Form GST25), you will now need to file it with the CRA. Further, any pre-2015 elections will also have to be filed before the end of 2015. Given the new filing requirements, this may be a good time to review...

 

HTMLDirectors Need to Meet High Standard to Avoid Liability
Alison J. Gray; Bennett Jones LLP;
Legal Alert/Article
January 23, 2015, previously published on December 16, 2014
The Tax Court of Canada again confirmed that directors of corporations will have a high burden to meet to establish a due diligence defence and avoid liability for unremitted source deductions.

 

HTMLRescission: Another Remedy to Address Unintended Tax Consequences
Alison J. Gray; Bennett Jones LLP;
Legal Alert/Article
January 23, 2015, previously published on January 6, 2015
While the equitable remedy of rectification is often sought as a means to address unintended tax consequences, rescission is also an available remedy in the appropriate cases. The British Columbia Supreme Court’s decision in Re 0741508 BC Ltd and 0768723 BC Ltd, 2014 BCSC 1791, is an example...

 

HTMLSupreme Court to Clarify the Liability of Canadian Corporations for Acts of their Foreign Affiliates
Alison J. Gray, Justin R. Lambert, David J. Wahl; Bennett Jones LLP;
Legal Alert/Article
January 23, 2015, previously published on December 11, 2014
The Supreme Court of Canada today heard argument in a case that will clarify whether a judgment obtained in a foreign country against a foreign corporate entity can be enforced in Canada against a Canadian affiliate of that foreign entity, even when the Canadian affiliate was not party to the...

 

HTMLNYC Proposed Tax Code Changes Would Affect Businesses Large and Small
Mark D. Allison, Rachel Leigh Partain, Clinton G. Wallace; Caplin & Drysdale, Chartered;
Legal Alert/Article
January 23, 2015, previously published on January 13, 2014
A proposal by the Mayor of New York City to change the City's corporate tax structure would, for the first time, tax certain businesses that have no physical presence in New York City but that do business in the City or with City residents. If adopted, the changes would take effect retroactively as...

 

HTMLStill On the Hook: How Calif. Taxpayers Often End Up With Ongoing Tax Liability
Jeremiah Coder, G. Michelle Ferreira; Greenberg Traurig, LLP;
Legal Alert/Article
January 22, 2015, previously published on November 20, 2014
It is surprising how often a California taxpayer receives a notice from the Franchise Tax Board (FTB) asserting an unpaid tax liability years after the general statute of limitations period has passed.

 

HTMLInflation Adjustments to Transfer Tax Provisions Provide New Opportunities in 2015
Withers Bergman LLP;
Legal Alert/Article
January 22, 2015, previously published on November 19, 2014
On October 30, 2014, the IRS announced in Rev. Proc. 2014-61 that there will be higher estate, gift, and generation-skipping transfer (GST) tax exemptions for tax year 2015 to account for inflation. These new thresholds provide additional estate planning opportunities to pass assets free from...

 

HTMLPrivate Equity: Cross-Border Acquisition Structures in the Line of Fire?
Graham Iversen; Greenberg Traurig Maher LLP;
Legal Alert/Article
January 22, 2015, previously published on November 26, 2014
In a discussion document published on 21 November 2014, the Organisation for Economic Co-operation and Development (the OECD) has acknowledged an issue which has been causing increasing concern in the international private equity community.

 

HTMLUpdate on VAT and Direct Mail
Withers Bergman LLP;
Legal Alert/Article
January 22, 2015, previously published on December 16, 2014
There have been fresh developments relating to the VAT treatment of outsourced mailing pack supplies, following intervention from Charity Tax Group and The Direct Marketing Association.

 

HTMLSwitzerland UK Autumn Statement 2014 Analysis
Withers Bergman LLP;
Legal Alert/Article
January 20, 2015, previously published on December 4, 2014
In yesterday’s Autumn Statement, the UK Chancellor announced several measures that will directly affect non-UK individuals who live or own property in or are considering moving to the UK. Although in many cases the measures will mean that such individuals are liable to pay more tax in the UK...

 


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