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HTMLBEPS Tail Shouldn’t Wag Global Investment Dog
Claire M.C. Kennedy; Bennett Jones LLP;
Legal Alert/Article
January 20, 2015, previously published on November 17, 2014
I spoke recently on a panel in Tokyo on the future of international tax planning after BEPS (the OECD’s & G20’s Action Plan to counter Base Erosion & Profit Shifting). The panel also featured a senior official at the OECD and practitioners from the US, Japan, Germany, France,...

 

HTMLInsurance Services
Withers Bergman LLP;
Legal Alert/Article
January 20, 2015, previously published on December 4, 2014
Insurance services are generally exempt from VAT. This ought to cover services of intermediaries, often called insurance brokers or insurance agents. The basic premise is that the broker intercedes between the person who needs the insurance and the person who can provide it. He usually has direct...

 

HTMLInternational Trade
Withers Bergman LLP;
Legal Alert/Article
January 20, 2015, previously published on December 4, 2014
People who provide services delivered through electronic means ('Electronic Services'), sold to final consumers based in other EU states, need to cope with the change of 'place of supply' rules from 1 January 2015.

 

HTMLSupreme Court of Canada to Decide if a Lawyer Subject to Enforcement Proceedings can Claim Solicitor-Client Privilege
Alison J. Gray; Bennett Jones LLP;
Legal Alert/Article
January 19, 2015, previously published on March 13, 2014
The Supreme Court of Canada recently granted leave to appeal in Minister of National Revenue v Duncan Thompson, 2013 FCA 197, which touches on the issue of whether a lawyer subject to enforcement proceedings can claim solicitor-client privilege over his accounts receivable.

 

HTMLWhat to be Mindful Of in 2015
Paul G. Topolka; Nexsen Pruet, LLC;
Legal Alert/Article
January 19, 2015, previously published on December 19, 2014
Taxpayers and representatives need to be mindful that the IRS Appeals Office has implemented what is known as the Appeals Judicial and Culture (AJAC) Project.

 

HTMLRevised CRA Policy Heralds Focus on Contemporaneous Transfer Pricing Documentation
Claire M.C. Kennedy; Bennett Jones LLP;
Legal Alert/Article
January 19, 2015, previously published on July 7, 2014
CRA released an updated transfer pricing memorandum, TPM-05R, Requests for Contemporaneous Documentation, in March, which describes the procedural aspects of transfer pricing documentation requirements in substantially more detail than its predecessor. The new policy document does not contain large...

 

HTMLA Last-Minute Stocking Stuffer from Congress: Individual and Business Tax Breaks Retroactively Extended
Steven M. Packer; Duane Morris LLP;
Legal Alert/Article
January 19, 2015, previously published on December 24, 2014
On December 16, 2014, Congress passed the long-awaited "Tax Increase Prevention Act of 2014" (TIPA or "the Act"), which President Obama signed into law on December 19, 2014, calling it a "substantial victory for middle-class families across the country." While this...

 

HTMLAlberta Court of Queen’s Bench Confirms Rectification Cannot Remedy Unanticipated Tax Consequences
Alison J. Gray; Bennett Jones LLP;
Legal Alert/Article
January 19, 2015, previously published on March 28, 2014
The recent decision of the Court of Queen’s Bench of Alberta in Graymar Equipment (2008) Inc v Canada (Attorney General), 2014 ABQB 154 is an important reminder of the limited nature of the equitable remedy of rectification in tax avoidance cases.

 

HTMLSaskatchewan Court Holds That Duty to Consult Not Triggered for Crown-Issued Oil Sands Exploration Permits
Laura M. Gill, Alison J. Gray; Bennett Jones LLP;
Legal Alert/Article
January 19, 2015, previously published on May 5, 2014
The Saskatchewan Court of Queen’s Bench held in Buffalo River Dene Nation v The Minister of Energy and Resources and Scott Land & Lease Ltd, 2014 SKQB 69, that a decision of the Minister of Energy and Resources to post for sale and subsequently issue two oil sands special exploratory...

 

HTMLHow Often Can I Rollover My IRA?
James A. Dressman; Dressman Benzinger LaVelle psc;
Legal Alert/Article
January 19, 2015
The previous position of the IRS with respect to indirect rollovers changed late last year effective January 1, 2015

 


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