The minister of finance recently tabled the government's 2015 Federal Budget, which proposes a number of business income tax, international tax, personal income tax and charity measures. The government's intentions in introducing these measures are to improve the fairness and integrity of the tax system, help the economy to grow, spur job creation and reduce the tax compliance burden.
A recent case concerned whether the taxpayer, the successor by amalgamation, was entitled to deduct in computing its income for its 2000 taxation year a sum of more than C$118 million paid to its employees for surrendering stock options under its employee stock option plan. The taxpayer contended that the amounts were paid as employee compensation to satisfy its obligations under the stock option plan.
Canada has proposed a regime of mandatory disclosure for certain tax avoidance transactions entered into after 2010, as well as transactions that are part of a series of transactions that began before 2011 but is completed after 2010. This update looks at the Department of Finance's new reporting rules and highlights their practical implications.
The Canadian minister of finance and the US secretary of the treasury have signed the Fifth Protocol to the Canada-US Income Tax Convention. The amendments and additions to the treaty contained in the protocol are significant and will have a major impact on the way in which Canada-US cross-border tax planning is implemented.