Ron Choudhury

Partner | Toronto

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The proposed new tax on share buybacks

With the release of the 2022 Fall Economic Statement, the Federal Government proposed a new tax on repurchases of equity by certain entities (the “Buyback Tax”). The draft legislative proposals and explanatory notes published by the Department of Finance on […]

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Securitisation: Canada

Mondaq Comparative Guides

Jason Kroft and Alfred Apps, with contributions from Ahmad Adam, Ron Choudhury, Simon Igelman, Asim Iqbal, Luc-Antoine Manneh,  Shaun Parekh and Margaret Shodeinde, author the Canada chapter for Mondaq’s Securitisation Comparative Guide. The guide provides a detailed analysis and comparison […]

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A primer on GST/HST costs within a securitization structure

When designing or negotiating a securitization structure, while commercial and non-sales tax issues may take precedence, GST/HST issues should be at the forefront of the structuring discussions in order to avoid tax leakage as a result of sales tax exposure. […]

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Release of draft Canadian tax legislation

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 […]

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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 […]

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E-Commerce Businesses – Do you need to be registered for GST/HST?

Effective July 1, 2021, major changes to the GST/HST regime as it relates to e-commerce and the digital economy came into effect. We previously reported on these measures when they were first announced in the Fall Economic Statement 2020 and […]

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No appeal of tax court decision in CanLII v. MNR

The decision of the Tax Court of Canada in CanLII v. MNR will not be appealed by the Minister of National Revenue. The case was argued on behalf of the registrant CanLII (Canadian Legal Information Institute) by Miller Thomson partners […]

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Rent deferral during pandemic may not reduce GST/HST payable on rent

The COVID-19 pandemic has created unique dilemmas or opportunities for all aspects of society. While select businesses are proving to be uniquely successful during the economic downturn, most businesses are in need of assistance in order to continue to exist. […]

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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 […]

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