Jan

Uber wants its users, its drivers and particularly the Canada Revenue Agency (the “CRA”) to agree that it does not provide “rides” to its “customers”. Instead, Uber Canada Inc. (“UCI”)...

Oct

US Shareholder of a Canco After 2017 Tax Reform

Posted By: Milosz Zak on October 31, 2018 at 2:00:08 in Articles

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Please see Sunita Doobay’s latest article for the Canadian Tax Foundation’s newsletter Canadian Tax Highlights which concerns Public Law no. 115-97 (2017 tax act) — the Tax Cuts and Jobs...

Oct

The Three Steps of GAAR

Posted By: Milosz Zak on October 2, 2018 at 2:43:58 in Articles , Case Comments

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Please see Vern Krishna’s latest article for the Taxnet Pro: Tax Disputes & Resolution Centre titled, “The Three Steps of GAAR” where he discusses the general anti-avoidance rule as a statutory...

Sep

Please see David Piccolo’s latest article for the September issue of the Tax Advocate titled, “A Review of Rectification in a Post-Fairmont World,” where he discusses the post Supreme Court of...

Sep

Please see Sunita Doobay’s latest article for the Canadian Tax Foundation’s newsletter Canadian Tax Highlights which covers the U.S. Treasury Department and IRS Notice 2018-29, which makes three exceptions to the...

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