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Recent GAAR Decision – Collins

By Marissa L Halil  LLB, BCL

A new case on the General Anti-Avoidance Rule (“GAAR”), Collins & Aikman Products Co. v. The Queen (“Collins“), was released by the Tax Court of Canada on June 3, 2009. The issue in Collins was whether the GAAR should apply to a reorganization which increased the paid-up capital (“PUC”) of shares.

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New chair of STEP Canada

Well, I arrived home this week after attending The Society of Trust and Estate Practitioners’ (“STEP”) 11th National Conference.  The conference contained many leading edge technical topics that dealt with tax and estate planning for the private client.  Membership in STEP, for me personally, has proved to be invaluable over the years given the tremendous worldwide membership that STEP has and the depth of knowledge of such members. 

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Tax conferences

Well … ’tis the season for professional development and education.  Every year, around this time, the professional tax conference season begins in earnest.  I had the pleasure of recently co-chairing the Canadian Tax Foundation Prairie Provinces Tax Conference which was held in Calgary on May 25 and 26, 2009.  What an outstanding group of tax professionals that gathered to listen to prominent speakers on relevant current tax topics.

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Prevost Car Inc. v. The Queen

By Nicolas Baas, LL.B., LL.M. (Tax)

On May 12, 2008 we posted a blog entry commenting on the Tax Court decision of Prevost Car Inc. v. The Queen TCC 231.  On February 26, 2009 the Federal Court of Appeal released its appeal decision in this case.The FCA endorsed the Tax Court’s decision in its entirety.  The facts of this case are straightforward and can be found in our May 12, 2008 blog.

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Opportunities in challenging economic times

Notwithstanding that financial markets and the economy continue to take a beating, there are significant tax planning opportunities that have not existed for quite some time.

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Lipson decision

By Kim G C Moody CA, TEP and Marissa L Halil LLB, BCL

The Supreme Court of Canada released its long awaited decision in Lipson v. Canada1 yesterday. The facts in Lipson were, very generally, as follows:

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Acquisition of US real estate

Apologies in advance … this is lengthy and a little technical but it’s a complex topic! Notwithstanding the recent weakening of the Canadian dollar, the decline in the value of US real estate may still present some attractive buying opportunities for Canadians.

The acquisition of US real estate by a Canadian resident not only has Canadian tax implications, but may also create US income, gift and estate tax consequences.

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Merry Christmas

Merry Christmas and Best Wishes for the New Year!

What a year! I certainly don’t recall a year as volatile and wild as the one that 2008 provided us. Overall, I would have to characterize it as a great year. How can you not when you are alive to breathe in the wonderful air, enjoy your family and friends, experience the natural beauty of our surroundings and enjoy our freedom. While 2008 also provided its share of volatility and financial tragedies, it also had many success stories.

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Non-resident trust and foreign investment entity legislation: Update

By Paul R. LeBreux, LLB, LLM, TEP (friend of Moodys LLP and principal of Global Tax Law Professional Corporation)

It has been almost 10 years to the day that Canada’s then Minister of Finance proposed new tax measures aimed at overhauling the method for taxing “non-resident trusts” and “foreign investment entities”.  These new tax measures were said to be needed to combat what the government had long perceived as an abuse of the Canadian tax system.  Since the introduction of the controversial initiative, the implementation of the legislation has been delayed numerous times and the Draft Legislation has been released, each time with substantial amendments, no less than six times.  Although the Draft Legislation continues to have an effective date of January 1, 2007, it would seem that the likelihood of these proposals being proclaimed as law has significantly diminished.

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Thaw transactions

By Nicolas Baass, LL.B., LL.M. (Tax)

As a follow-up to our November 24, 2008 blog entry regarding tax planning during uncertain times, another tool that should be considered is the so-called estate “thaw” or “refreeze.” As discussed in the November 24, 2008 entry, a freeze is a powerful succession planning tool. It could possibly be made even more potent by refreezing in these uncertain times.

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