Federal Court of Appeal affirms application of Subsection 84(2) of the Income Tax Act (Canada) to a hybrid business sale transaction
In the context of a sale of a business operated by a corporation, the seller and buyer typically have competing interests. Whereas sellers tend to prefer selling their shares of the corporation so that they can receive the sale proceeds […]
The increasing popularity earnouts
Due to the economic impact of the COVID-19 pandemic and the recent volatility of stock markets, we have noticed an increased perceived valuation gap between vendors and purchasers in the context of M&A transactions. As a result, contingent consideration arrangements […]
Changes to the substantive CCPC rules
On August 9, 2022, legislative proposals relating to the Income Tax Act (the “Act”) and other tax legislation were released by the Department of Finance for public feedback (the “August Proposals”). The August Proposals seek to implement certain measures previously […]
Release of draft Canadian tax legislation for public consultation
An extensive package of draft legislative proposals was released for public comment by the Department of Finance on February 4, 2022 (the “Proposals”) along with explanatory notes (the “Notes”). The Proposals include some, but not all, of the measures announced […]
Canada Emergency Wage Subsidy: Revised rules for qualifying periods August through December
Bill C-20, An Act respecting further COVID-19 measures (“Bill C-20”), received Royal Assent on July 27, 2020. Bill C-20 enacts amendments to provisions of the Income Tax Act (Canada) that implement the Canada Emergency Wage Subsidy (“CEWS”). These amendments include […]
COVID-19: Sales tax and tax controversy updates and insights
Businesses of all sizes are scrambling to adapt to the constantly changing world in which we find ourselves. Owners are worried about cash flow. Routine business operations are migrating online. New revenue streams are being explored. Meanwhile, we are inundated […]
