Providing crossborder inter-company goods or services? Don’t forget about transfer pricing!
In the transportation and logistics industry, as with other industries, it is common for corporations in the same multinational group to provide goods and services to one another. If the parties to such a transaction include a Canadian taxpayer (for […]
Canadian surtax on imported goods: Consultation window closes October 10, 2024
Introduction Increased electric vehicle (“EV”) production is a key global strategy for addressing climate change. However, Canada’s auto manufacturing industry faces what the Government of Canada has described as an “extraordinary threat” from Chinese-produced EVs. In 2020, China emerged as […]
Changes to employee stock option deduction calculation
In the 2024 Federal Budget, the Department of Finance announced that capital gains realized by individuals on or after June 25, 2024 in excess of an annual $250,000 threshold will be subject to a two-thirds inclusion rate for purposes of […]
Demystifying par value shares: tax advisors beware
Par value shares are often considered one of the last vestiges of the old Canadian corporate legislation. The current federal corporate legislation, and the majority of provincial corporate legislation, no longer permit the issuance of par value shares. However, the […]
Proposal to amend the valuation for duty regulations
The Canada Border Services Agency (“CBSA”) is proposing amendments to the Valuation for Duty Regulations (Canada) (the “Regulations”). The CBSA takes the position that the current valuation rules provide an unfair advantage to non-resident importers (“NRIs”). The CBSA notes that […]
Canada’s action to eliminate forced labour and child labour
Introduction In furtherance of Canada’s commitment to eliminate forced labour and child labour, the Fighting Against Forced Labour and Child Labour in Supply Chains Act (Canada) (the “Act”) received Royal Assent on May 11, 2023.[1] The Act imposes reporting obligations […]
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 […]
The new Underused Housing Tax: Are you tax exempt?
The Underused Housing Tax (the “UHT”) is a new annual 1% tax payable by an “owner” (other than an “excluded owner”) of “residential property”. A “residential property” includes, among other things, a detached house, a duplex, a triplex, a row-house […]
When do you need to charge GST/HST on chargebacks?
Many trucking companies have entered into arrangements with subcontracted carriers or owner-operators/contractors for charges such as fuel, insurance, or licensing fees. Anyone who has entered into such an arrangement should review their contracts from a GST/HST perspective. While the nature […]
Federal Government targeting independent contractor arrangements with road transportation workers
Businesses in the trucking industry may soon face increased scrutiny from the Federal Government respecting the classification of drivers as independent contractors. With the release of the 2022 Fall Economic Statement, it was announced that the Federal Government will allocate […]