Countdown to December 31 QST and Pension Plan Changes
December 22, 2010
December 31, 2010 will not only bring an end to a year that has seen its fair share of sales tax changes but will also bring two more significant changes for many businesses in the form of new GST/HST pension plan rules and an increase to the Quebec Sales Tax (QST) rate.
Finance Eases REIT Rules
December 22, 2010
With the release of new proposals regarding real estate investment trusts (REIT) on December 16, 2010, the Department of Finance has responded to concerns of the real estate industry regarding the exemption for these entities from the new tax on specified investment flow-through (SIFT) entities.
GE Capital – FCA Upholds Canco’s Guarantee Fees in Transfer Pricing Case
December 21, 2010The Federal Court of Appeal of Canada (FCA) recently upheld the Tax Court of Canada (TCC) transfer pricing decision in The Queen v. General Electric Capital Canada Inc. (2010 FCA 344) that guarantee fees paid by GE Capital Canada to its foreign parent met the arm’s-length principle.
Canada Launches Review of Taxation of Corporate Groups
December 2, 2010
The Department of Finance launched formal consultations on the taxation of corporate groups on November 23, 2010 and released a 33-page paper to help guide the debate.
Resolving Canada-U.S. Double Tax Disputes through Arbitration – New Guidance
December 1, 2010
The Canada Revenue Agency (CRA) and Internal Revenue Service (IRS) recently released details on the new procedure to be followed by the Canadian and U.S. competent authorities for cases proceeding to arbitration under the Canada-U.S. tax treaty.
Owner-Managers — Act Now for 2010 Tax Savings
November 24, 2010
Even though 2010 is almost over, it’s not too late to take action to save taxes for yourself and your incorporated business this year.
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Year-end Tips for Reducing Your 2010 Personal Tax Bill
November 23, 2010
As another year draws to a close, many Canadians are looking for ways to improve their financial well-being.
Trusts — Time for a Residency Review and Year-End Tax Planning
November 22, 2010
If you have a family trust and it’s set up in another country or a province other than the one where you reside, now is a good time to review its arrangements in light of a recent court decision.
Highlights of the New Canada — Swiss Tax Treaty Protocol
November 11, 2010
Canada and Switzerland signed a new protocol to amend the tax treaty between the two countries on October 22, 2010.
Joint International Tax Audits — Coming to Canada Soon?
October 8, 2010
In its efforts to boost international tax compliance, the OECD’s Forum on Tax Administration is moving beyond cooperation to coordinated action. Following on the Forum’s success in encouraging the international adoption of standards for tax information exchange — now incorporated into over 500 tax treaties and tax information exchange agreements worldwide — the Forum recently sanctioned bi- and multilateral tax compliance audits and issued guidelines for conducting them.
Canada-U.S. Tax Treaty — IRS and CRA Shed Light on Mandatory Arbitration
October 5, 2010
The first wave of double taxation cases that have recourse under the Canada-U.S. tax treaty’s mandatory arbitration procedure will become eligible for the procedure on December 15, 2010. But until recently, details on how mandatory arbitration will operate have been unknown. At a recent panel discussion, the two most senior IRS and CRA competent authority representatives offered some preliminary guidance on the new mandatory arbitration process.
Revisit Global Structures in Light of Canada’s New Tax Agreements
August 27, 2010
Canada has signed nine tax information exchange agreements (TIEA) with non-treaty countries to date and is negotiating with 14 other jurisdictions. Global organizations with investments or operations in these countries or other low-tax jurisdictions should review their international business or financing structures in light of these new agreements.
Ontario Retailers — Get Ready for More GST/HST Reporting Requirements
August 9, 2010
Ontario retailers face new GST/HST reporting requirements for the upcoming new point-of-sale rebate of the 8% provincial component of the HST for qualifying off-reserve goods and services purchased by First Nations customers.
GlaxoSmithKline Inc. — Taxpayer Wins But at What Price?
August 5, 2010
The Federal Court of Appeal (FCA) has reversed the Tax Court of Canada (TCC) decision in GlaxoSmithKline Inc. v. The Queen.
CRA Audit Approach to Focus on Tax Governance of Large Corporations
July 29, 2010
The Canada Revenue Agency is reviewing its audit program and processes to reflect the tax filing and compliance history and tax governance structure of large corporations.
New GST/HST Rules for Pension Plans Increase Employers’ Costs
July 28, 2010
Many employers with pension plans will have to start remitting GST/HST related to these plans in the next few months under recently enacted new rules.
Transfer Pricing News — Completed Advance Pricing Arrangements on the Rise
July 23, 2010
The CRA’s 2009-2010 Advance Pricing Arrangement (APA) Program Report shows that interest in the program continues to be strong.
CRA Issues Advice on IFRS Start-up and Tax Reporting
June 8, 2010
With the pressure on tax departments to understand and manage IFRS transition matters, the CRA’s new advice on how the change will affect tax reporting is timely and welcome.
More FIs Face Complex Rules for Calculating HST Costs
June 1, 2010
Many financial institutions will have to change the way they calculate the GST/HST they pay, effective July 1, 2010. Investment funds will become subject to the complicated rules known as the Special Attribution Method (SAM) for the first time. Other financial institutions already subject to these rules will have to adjust their systems for changes to the provincial allocation portion of the SAM calculation.
New HST Rules Take Effect May 1
April 30, 2010
A reminder to businesses – you must start collecting Ontario and British Columbia’s new harmonized sales tax (HST) on payments made or invoices issued on or after May 1, 2010 for supplies of goods and services made in those provinces on or after July 1, 2010 (i.e., prepayments). Also coming into effect are new place of supply rules for HST.
HST Employee Expense Factors Released
April 28, 2010
With this release, many employers can now adjust their IT systems, but large businesses may have to wait.
GST on Financial Services — Confusion Clarified?
April 12, 2010
Financial institutions and businesses providing services to them got some welcome news recently when the Finance Minister clarified the government’s intention behind its redefinition of “financial services” for GST purposes.
Sales Tax Rate Hikes Spur Complexity and Business Risk
April 7, 2010
Over the last few months, Canadian sales taxes may have become a much greater risk for your business.
2010 Quebec Budget Highlights
March 30, 2010
Québec Finance Minister, Raymond Bachand, tabled today, March 30th, 2010, the Québec provincial budget plan for 2010-2011. Members of KPMG’s tax practice attended the budget lock-up in Québec City and prepared a new edition of TaxNewsFlash-Canada summarizing the proposed tax changes.
2010 Ontario Budget Highlights
March 25, 2010
Ontario Finance Minister Dwight Duncan delivered the province's 2010 budget on March 25, 2010.
Canada Exempts More Non-resident Investors from Capital Gains Tax
March 24, 2010
Many non-resident investors stand to benefit from the 2010 federal budget’s changes to the definition of "taxable Canadian property".
2010 Manitoba Budget Highlights
March 24, 2010
Manitoba Finance Minister Rosann Wowchuk tabled the province’s 2010 budget on March 23, 2010.
Time to Rework Corporate Stock Option Plans
March 23, 2010
Companies that offer stock option plans to their employees may have to quickly re-evaluate these arrangements following significant changes to the tax treatment of stock options announced in the 2010 federal budget. Many of these changes are effective for stock options exercised after 4:00 pm (EST) on March 4, 2010.
Chinese Tax Developments Re-draw the Map for Canadian Investors
March 19, 2010
Canadians doing business in China may have a hard time keeping up with the country's rapid pace of tax reform.
Charities’ Spending Rules Eased Starting in 2010
March 12, 2010
Registered charities received some welcome news in the 2010 federal budget. The government proposes to ease the rules that determine how much a charity must spend each year on its charitable activities. These changes will apply for charities’ fiscal years ending on or after March 4, 2010.
Highlights of the 2010 Federal Budget
March 4, 2010
Finance Minister Jim Flaherty delivered Canada’s 2010 federal budget earlier today on March 4, 2010. Members of the KPMG National Tax Centre attended the budget lock-up in Ottawa and have prepared a new edition of TaxNewsFlash-Canada summarizing the announced tax changes.
2010 British Columbia Budget Highlights
March 2, 2010
B.C. Finance Minister Colin Hansen tabled the province’s 2010 budget update on March 2, 2010.
New HST Place of Supply Rules Unveiled
February 26, 2010
Businesses selling goods and services in Canada may need to change their systems and processes for collecting tax on their sales following the Department of Finance’s release on February 25, 2010 of significant proposed changes to the harmonized sales tax (HST) “place of supply” rules.
CRA Narrows GST-Exempt Financial Services
February 16, 2010
Many financial institutions and businesses who provide services to them may be affected by a recent Canada Revenue Agency notice that, surprisingly, seems to significantly limit the number of services considered GST-exempt “arranging for” financial services.
RRSPs versus TFSAs — Getting the Most out of Your Savings Plan
February 12, 2010
With the March 1, 2010 deadline for 2009 tax-deductible RRSP contributions coming up soon, now is a good time to weigh the advantages of tax-assisted savings plan options.
Ontario and B.C. HST Only Months Away — Are You Ready?
February 8, 2010
Since Ontario and British Columbia announced they would harmonize their provincial sales taxes with the federal Goods and Services Tax (GST), they have been releasing details on how this new harmonized sales tax (HST) will work in each province.
Tax Cost of Canadian Financing Structures to Rise Under New U.S.-Hungary Tax Treaty
February 2, 2010
If your organization uses a Hungarian-based structure to finance its U.S. operations, the U.S.-Hungary tax treaty signed on February 4, 2010 will affect the structure’s tax benefits.
Converting SIFTs to Corporations - What's Your Game Plan?
February 2, 2010
If you’re involved with a trust or partnership that is a “specified investment flow-through” (SIFT) or real estate investment trust (REIT) that will become taxable in 2011, a variety of issues will affect your decision on whether and when to convert to corporate form.
Is Your Family Trust Ready for its Close-Up?
February 2, 2010
If you have a family trust, it’s a good idea to periodically review your trust arrangements to confirm they are working properly and providing the tax results you want.
CRA Reports Growing Interest in Advance Pricing Agreements
January 22, 2010
A CRA program report says that the CRA concluded 10 APAs in 2008-09, up from eight completed APAs in 2007-08
The Clock is Ticking - Accounting for Taxes in Your IFRS Conversion Plan
January 20, 2010
IFRS will replace Canadian GAAP for fiscal periods starting in 2011, and companies need to be ready to deal with some significant differences in accounting for taxes between the two standards.