Canadian Tax Legislation and Case Law: Recent Developments

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An update on recent developments in Canadian tax legislation and case law.

Speakers include: Monica Biringer, Amanda Heale, Andrew Kingissepp, Al Meghji, Matias Milet and Jack Silverson.

Topics include the following.

Interest Deductibility:

– the recent decisions in TDL Group and ENMAX;
– draft amendments to the back-to-back loan provisions in the thin capital rules; and
– the proposal to extend the application of the thin capital rules to corporations in which pension plans have a significant interest.

Cross-Border Developments:

– the recent decision in Univar relating to subsection 212.1 of the ITA;
– the proposed amendments to subsection 212.1 of the ITA; and
– the impact of the Common Reporting Standard rules.

Tax Disputes:

– proposed amendments to subsection 152(9) of the ITA which provide the CRA with greater latitude to raise additional arguments; and
– a discussion of recent and upcoming cases.


Ben Cen says:

Good discussion with a large volume of relevant recent court cases

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