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Final US related-party debt regulations will impact US subsidiaries of Canadian parent companies

On October 13, the US Treasury Department and the IRS released new final and temporary Section 385 regulations (TD 9790) addressing the treatment of related-party debt. [October 27, 2016] More...

Changes to principal residence exemption–trusts and non-residents

On October 3, 2016, Federal Finance Minister Bill Morneau announced changes which will affect trusts and non-residents owning residential property in an effort to ensure “housing markets are stable and functioning efficiently.” [October 26, 2016] More...

Welcome to the future: Getting the most out of Budget 2016

An article by Martha Oner and Glen Gilbert. PLANT July/August 2016 issue. [August 23, 2016] More...

Department of finance releases draft legislation for country-by-country reporting

In October 2015, the Organization for Economic Co-operation and Development (OECD) released its Base Erosion and Profit Shifting (BEPS) Action 13, focused on new country-by-country (CbC) reporting requirements for large multinational enterprises (MNEs). [August 19, 2016] More...

CRA’s new position on US LLLPs and LLPs

On May 26, 2016, the Canada Revenue Agency (CRA) announced that it will consider Florida and Delaware limited liability limited partnerships (LLLPs) and US limited liability partnerships (LLPs) to be corporations for Canadian tax purposes. [July 26, 2016] More...

ITC recapture: Second stage of phase-out for Ontario HST

Large businesses that exceeded $10 million in taxable and zero-rated revenues during their last fiscal year are required to recapture a portion of their input tax credits (ITCs) claimed in respect of the provincial part of the Ontario HST paid or payable on specified property and services. The first stage of the phase out of the recapture rate began on July 1, 2015. Starting July 1, 2016, the second stage of this recapture rate phase out will commence. [June 16, 2016] More...

2016 Saskatchewan budget summary

On June 1, 2016, Saskatchewan’s finance minister, Kevin Doherty, tabled the province’s 2016-17 budget. The budget forecasts deficits of $427.2 million for the 2015-2016 fiscal year and $434.2 million for the 2016-17 fiscal year. A small surplus of $6 million is projected for 2017-18. After setting aside a small contingency allowance for planning purposes, surpluses of $55 million and $97 million are projected over the subsequent two years. [June 2, 2016] More...

2016 Manitoba budget summary

On May 31, 2016, Manitoba Finance Minister Cameron Friesen tabled the province’s 2016-17 budget. [June 1, 2016] More...

China tax alert: a new era of VAT

On 23 March 2016, Ministry of Finance(MOF) and State Administration of Taxation (SAT) of the People’s Republic of China (PRC) jointly issued “Notice of Taxation on Full Launch of the Pilot Scheme on Levying Value-added Tax in Place of Business Tax” Caishui [2016] 36 (Circular 36), which indicates that with effect from 1 May 2016, the transformation of pilot programme from Business Tax to VAT (B2V Reform) will cover sectors of construction, real estate,financial services and consumer services and China enters into a new era of VAT. [May 25, 2016] More...