Grant Thornton Feed: Insights [articles]

The not-so-thin “thin-capitalization” rules

2012-04-19T14:31:09-05:00

The Income Tax Act (Canada) (ITA) contains rules which limit the deductibility of interest expense that is incurred by a Canadian-resident corporation where the amount of interest-bearing debt owed to certain non-residents exceeds a 2-to-1 debt-to-equity ratio. click to open PDF

Supreme Court of Canada addresses residency of trusts

2012-04-17T16:26:36-05:00

On April 12, 2012 the Supreme Court of Canada (SCC) released its unanimous decision on the issue of the residency of a trust for the purpose of determining the trust’s Canadian income tax liability and reporting obligations. Of key importance was the SCC’s finding that the residency of a trust should be determined not necessarily by the residence of the majority of its trustees, but rather by the location where the central management and control of the trust resides or was exercised. click to open PDF

New rules for EPSPs

2012-04-16T13:58:22-05:00

For many years Employee Profit Sharing Plans (EPSPs) have been used to defer tax and provide income splitting benefits. These plans have also been promoted on the basis that allocations from an EPSP are not subject to CPP and EI premiums. click to open PDF

The impact of the Federal budget on Scientific Research and Experimental Development

2012-04-05T14:48:14-05:00

According to several economic studies, Canada continues to lag behind peer countries in terms of overall innovation performance. This is particularly true for private sector investment in research and development (R&D) and the commercialization of research into products and processes—two sectors that create high-value jobs and economic growth. click to open PDF

Does your RRSP or RRIF own shares which have become a prohibited investment?

2012-03-15T13:13:05-05:00

New anti-avoidance rules for RRSPs and RRIFs introduced in the 2011 federal budget could mean that shares that were previously a “qualified investment” for RRSP/RRIF purposes may now have become a “prohibited investment.” click to open PDF

History repeating

2012-02-22T14:56:52-05:00

Highlights of the Federal and British Columbia HST Transitional Rules, as released February 17, 2012. click to open PDF

GST/HST registration: Change to the rules for voluntary registration

2012-02-17T10:05:41-05:00

The CRA has recently changed its administrative policy around the timelines for voluntary registration of GST/HST. This means that every new business should likely be registered immediately, if the expectation is that it might make an acquisition in respect of a commercial activity. click to open PDF

Straight from the source—Canada’s first Supreme Court transfer pricing case

2012-02-07T09:27:46-05:00

On January 13, 2012, arguments were heard by the Supreme Court of Canada in the matter of Her Majesty the Queen v. GlaxoSmithKline Inc. The case involves the pricing of intercompany transactions between Glaxo Canada, a Canadian corporation, and related corporations in the United Kingdom and Switzerland, Glaxo Group Ltd. (“Glaxo Group”) and Adechsa S.A. (“Adechsa”), respectively, during the 1990 to 1993 taxation years. The appeal was brought by the Crown. click to open PDF

Grace period ends for most tax-exempt entities

2012-01-10T14:05:14-05:00

Municipalities and most other tax-exempt entities that do not complete and file their corporate income tax returns may find that their GST/HST rebates and refunds will be withheld by the Canada Revenue Agency (CRA). click to open PDF

Elimination of tax deferral for joint venture participants

2011-12-16T10:16:42-05:00

Since 1989, the Canada Revenue Agency (CRA) has administratively permitted a joint venture (JV) to have a fiscal period that was different from the fiscal periods of the JV participants. In many cases, this policy has allowed a JV participant to realize a tax deferral similar to that enjoyed by corporate partners of a partnership. click to open PDF

2011-12-09T14:40:59-05:00

The IRS has recently released a fact sheet to address a number of issues of concern to US citizens or dual citizens who reside outside of the US. The issues revolve around the failure to make certain required filings—specifically, federal income tax returns and Reports of Foreign Bank and Financial Accounts (FBARs). click to open PDF

2011-12-06T11:44:18-05:00

On January 1, 2012, the Quebec Sales Tax (QST) will increase by 1% to 9.5%. click to open PDF

Upcoming changes to the CPP rules

2011-11-30T17:24:25-05:00

The Canada Pension Plan (CPP) rules are changing, with the majority of these changes effective January 1, 2012. These new rules will impact you if you’re between the ages of 60 and 70, and have either started collecting CPP benefits or will soon have to decide when to start collecting benefits. click to open PDF

Donating public company shares to a charity

2011-11-24T09:56:58-05:00

Have you ever considered donating publicly traded securities such as stocks and bonds to a charity? This is a smart and tax-effective alternative to the donation of cash. How you structure your charitable donations can be as important as the amounts you give—both for the charity and for you as the donor. click to open PDF

2011-11-24T09:55:27-05:00

An overview of the developments that came out of the three-day conference where representatives of OECD member country tax administrations met with multinational businesses and experts to discuss the future of the transfer pricing aspects of intangible assets. click to open PDF

Action required: pension plans must provide information by November 15

2011-11-11T14:06:33-05:00

Pension and other investment plans that invest in distributed investment funds and other investment plans may be required to provide certain information without receiving a formal request. click to open PDF

Quebec and Canada sign memorandum of agreement for sales tax harmonization

2011-11-07T09:20:33-05:00

In a joint news announcement earlier today with Premier Jean Charet, Prime Minister Stephen Harper has agreed to pay $2.2 billion to the Quebec government to compensate for the cost of harmonizing its provincial sales tax with the federal goods and services tax 20 years ago. click to open PDF

2011-11-03T14:52:29-05:00

A recent Supreme Court of Canada (SCC) decision, Dubé v The Queen, has resulted in a significant change in the legal landscape with regard to the tax exempt status of interest income for members of the First Nations community click to open PDF

Update on private and public company shares held in your RRSP

2011-10-20T10:27:34-05:00

If you hold private or public company shares in your RRSP, new measures originally proposed as part of the 2011 federal budget could have an impact on you. click to open PDF

Draft rules address private company shares held in your RRSP

2011-10-17T09:55:27-05:00

If you hold private company shares in your RRSP, new measures originally proposed as part of the 2011 federal budget could have an impact on you. click to open PDF