JULY 2017 EXECUTIVE TAXBRIEFS - LINKS EDITION

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A. Tax Legislation

Late Breaking News - Ottawa Hammers Income Sprinkling

July 18, 2017:   Ottawa has unveiled a series of new measures to significantly restrict the ability of high-income Canadians to use private corporations to reduce their tax bills, including th...

1. Budget Dates 2017

Federal - March 22, 2017Alberta - March 16, 2017British Columbia - February 21, 2017Manitoba - April 11, 2017New Brunswick - February 7, 2017  Newfoundland &...

2. Proposed Federal Tax Legislation - Including Budgets

The Department of Finance Website links all pending/draft tax legislation on its website, including the recent Federal Budget introduced by Notice of Ways and Means Motion on the same day as the Fe...

3. Status of Tax Treaties

For the Status of International Tax Treaty Negotiations on the Department of Finance website, scroll down past the yearly Notices to see the: In Force; Signed but Not Yet In Force and Und...

4. Tax Rate Links

KPMG -Digital Tax Facts 2016-2017 April 30, 2017 CRA - Individual Tax Rates, Corporate Tax Rates BDO - Personal Tax Rates 2017, Corporate Tax Facts 2017 E ...

5. 2017 Federal Budget Commentaries

Aird & Berlis Stikeman Elliot – GST/HST Blake Cassels & Graydon Moodys Gartner McCarthy Tetreault BDO KPMG  Deloitte PWC

6. 2017 Provincial Territorial Budgets - Deloitte

B. CRA's Interpretations

7. No Treaty relief from double taxation for a LLC with U.S.-source income and single Canadian-resid

No Treaty relief from double taxation for a LLC with U.S.-source income and single Canadian-resident member

8. CRA Proposes Sweeping Changes to Voluntary Disclosures Program

CRA Proposes Sweeping Changes to Voluntary Disclosures Program See slso BLG article, "Canada Revenue Agency Proposes Sweeping Changes to Voluntary Disclosures Program".

9. Family expenses paid by discretionary family trust must be unequivocally for the benefit of the 

Family expenses paid by discretionary family trust must be unequivocally for the benefit of the  child beneficiary's benefit - CRA Q. 10 June 2017 STEP

10. Medical clinic receiving a share of the clinic doctors’ billings supplying GST/HST taxable admin

Medical clinic receiving a share of the clinic doctors’ billings to the provincial health care plan was supplying GST/HST taxable administrative services - CRA

11. TI 2016-0649841E5 F - Dividend Refund to Private Corporation

TI 2016-0649841E5 F - Dividend Refund to Private Corporation - Although a private corporation with an available claim for a dividend refund (“DR”) is not required to make the claim...

12. TI 2016-0679751E5 F Tr - a “survivor payment” can be made out of TFSA ok when made in executor’s

T.I. 2016-0679751E5 F Tr - a “survivor payment” can be made out of the deceased’s TFSA even where this occurs in the executor’s discretion

13. CRA comments on the Uber GST/HST amendment

C. Tax Court Cases

14. Estate of Norman Frank Berkner - B.C. Multiple Wills

Does Berkner Estate Case resolve validity of Multiple will in B.C.? See decision of BCSC  CVTrsutCo Blog

15. TCC finds that value-shift scheme were included as part of an estate-freezing purpose - 2763478

TCC finds that value-shift scheme was included as part of an estate-freezing purpose - 2763478 Canada (2017 CCI 98 ) See Tax Interpretations

16. Series of transactions can inform whether a bad s. 74.5(11) purpose - taxpayer not responsible u

TCC Mady decision (2017 TCC 112) finds that the series of transactions can inform whether an included property transfer has a bad s. 74.5(11) purpose, and that the taxpayer is not responsible under...

D. Practitioners' Forum

17, STEP Canada CRA Roundtable, June 13, 2017  - Gowlings

STEP Canada CRA Roundtable, June 13, 2017  - Gowlings Link    See also Tax Interpretatations Copmmentary Topics Covered: 1.       Paragraph (b) ...

18. Key considerations on the new small business deduction denial rules

Key considerations on the new small business deduction denial rules

19. The impact of high personal and corporate tax rates

The impact of high personal and corporate tax rates

20. Less Relief under Draft GST VDP Guidelines - KPMG

 Less Relief under Draft GST VDP Guidelines - KPMG

21. CRA announces arrangement with IRS on country-by-country reports.

CRA announces arrangement with IRS on country-by-country reports.

22. Finance Targets Private Company Tax Planning - KPMG

Finance Targets Private Company Tax Planning - KPMG

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