Blakes Bulletin on Tax
This publication reports on topical developments on a frequent basis and
is published by
the Tax Group at Blake, Cassels & Graydon LLP.
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February 2007
Bill C-28:
Designating "Eligible Dividends"
[pdf / Adobe Acrobat version] 
Quebec Budget: Highlights of Certain Measures Concerning Businesses
[pdf / Adobe Acrobat version]
Securities
Canadian Income Trust
M&A
[pdf / Adobe Acrobat version]
January 2007
Bulletin on Tax
Taxation of Income Trusts and Other SIFT Trusts
[pdf / Adobe Acrobat version]
December 2006
Bulletin on Tax
Income Trusts Announcement
Department of Finance Provides
Guidance on “Normal Growth” for Income Trusts on
December 15, 2006
[pdf / Adobe Acrobat version]
November 2006
Bulletin on Taxation
Imperial Oil – The Supreme Court of Canada Considers Foreign Exchange Losses and Exchangeable Debentures
[pdf / Adobe Acrobat version]
Bulletin on Taxation
Canadian Minister of Finance Announces a Proposed New Tax Regime for Income Trusts and Public Limited Partnerships
[pdf / Adobe Acrobat version]
September 2006
Bulletin on Cross-Border Taxation
Favourable Decision in Treaty Shopping Case - Kathleen Penny
International Financial Centres in Montréal - John Leopardi
Mutual Fund Trusts and Part XIII.2 Tax - Kenneth Snider
[pdf / Adobe Acrobat version]
June 2006
Bulletin on Securitization
CANADIAN SECURITIZATION UPDATE
Capital Tax Elimination – Implication for Cross-Border Securitization - Martin Fingerhut & Kathleen Penny
[pdf / Adobe Acrobat version]
Bulletin on Mergers & Acquisitions Tax
Structuring Share Acquisitions - A Basic Primer - Leslie Morgan
Proposed Amendments On Tax Cost And Expenses - Ron Richler
Considerations In Income Trusts, Royalty Trusts And REITs Acquisitions - Kenneth Snider
[pdf / Adobe Acrobat Version]
March 2006
Bulletin on Cross-Border Taxation
Ownership Structures for Non-Canadian Investors in Canadian Real Estate - Jeffrey Trossman
Cross-Border Debt Financing of Canadian Real Estate — The 5/25 Exemption from Withholding Tax - Kathleen Penny & Kenneth Snider
Dispositions by Non-Residents of Canadian Real Property — Taxation & Compliance Requirements - Joel Shafer
U.S. Tax-Exempt Organizations Investing in Canadian Real Estate - Kenneth Snider
[pdf / Adobe Acrobat Version]
November 2005
Bulletin on Cross-Border Taxation
Income Trusts — Minister of Finance Announces Changes - Kenneth Snider & Jeffrey Trossman
How Much Can the CCRA Learn About Your Business? - Jean Gagnon
Canada Revenue Agency Rules U.S. Partnership Qualified for Treaty Benefits - Kathleen Penny
Québec Employers Beware — The New Québec Parental Insurance Plan - John Leopardi
[pdf / Adobe Acrobat Version]
October 2005
Bulletin on Taxation
The Supreme Court of Canada Provides Guidance on the General Anti-Avoidance Rule - Edward Rowe & David Spiro
[pdf / Adobe Acrobat Version]
June 2005
Bulletin on Cross-Border Taxation
A Recent Canadian Tax Development in Respect of a Conversion of a Delaware Limited Liability Company into a Delaware Limited Partnership - Kenneth Snider & David Spiro
[pdf / Adobe Acrobat Version]
Bulletin on Taxation
Canadian and U.S. Competent Authorities Agree to Get the Mutual Agreement Process Back
On Track - Janice McCart & Joel Shafer
[pdf / Adobe Acrobat Version]
May 2005
Bulletin on Cross-Border Taxation
UPDATE - Alberta Unlimited Liability Corporations - Doug Richardson & Wanda Rumball
Canadian Federal Appeal Court Decision Broadens Scope of Withholding Tax - David Spiro & Edward Rowe
Québec Budget - Highlights of the Measures Concerning Business - Jean Gagnon & John Leopardi
Non-Resident Funds Engaging Canadian Service Providers - Kenneth Snider
Subsection 95(6) - More Power than GAAR - Leslie Morgan
[pdf / Adobe Acrobat Version]
April 2005
Bulletin on Tax and Corporate Finance
Cross-Border Debt Financing of Canadian Enterprises
A Primer on the 5/25 Exemption from Withholding Tax - Kenneth Snider & Kathleen Penny
Arm’s Length and Back-to-back Loans - Bill Maclagan
The Corporate Borrower Requirement and Back-to-back Loans - Kathleen Penny
Excluded Interest — The Post-amble to Paragraph 212(1)(b) - Chris Van Loan
Cash Collateral Requirements - Leslie Morgan
Is the CRA Adverse to a Material Adverse Change Default? - Paul Stepak
CRA’s Acceptance of “Triggering Events” - Sheldon Vanderkooy
[pdf / Adobe Acrobat Version]
March 2005
Bulletin on Taxation
Alberta Unlimited Liability Corporations - Dallas Droppo & Doug Richardson
[pdf / Adobe Acrobat Version]
Bulletin on Cross-Border Taxation
American
Jobs Creation Act of 2004 — Interest Deductibility Issues on Payment
of Dividends from Canada - Joel
Shafer
"Permanent Establishment" Under The Ontario Employer Health Tax Act - David Spiro
Cross-border Guarantees — Some Transfer Pricing Relief - Chris Van Loan
The Canadian Problem with Limited Liability Companies — A Self-help Approach - Kenneth Snider
[pdf / Adobe Acrobat Version]
2005 Federal Budget - Proposed Elimination of Foreign Property Tax
Bulletin on Taxation
Canada Enhances Tax Incentives for Green Energy Projects - Bill Maclagan
[pdf / Adobe Acrobat Version]
November 2004
Bulletin on Cross-Border Taxation
Application of Treaty Benefits to Partnerships - Bill Maclagan
Cross-Border Securities Lending — Still Problematic - Chris Van Loan
Direct Investment in Canadian Real Estate - Kenneth Snider
Back-to-Back Loans and the 5/25 Withholding Tax Exemption - Kathleen Penny
[pdf / Adobe Acrobat Version]
October 2004
Appeal Court Allows Partial Deduction of Currency Losses in Connection with Borrowing - Jeff Trossman, Paul Tamaki & David Spiro
September 2004
Draft Tax Amendments for Mutual Fund Trusts and Corporations - Jeff Trossman
Special Alert from Tax Notes International (Sept. 20, 2004)
What is Past is Prologue:
The Supreme Court of Canada
to Consider the GAAR - David Spiro
April 2004
Bulletin on Mergers and Aquisitions
Relief From Double Counting of CPP Contributions and EI Premiums - Paul Tamaki & Paul Stepak
Update on Foreign Affiliates - Chris Van Loan
Distributions of Capital by Public Corporations - Joel Shafer
No Competing With Finance — Taxing Non-Competition Payments - Jeffrey Trossman & Bryan Bailey
Income Trust Conversions - Kenneth Snider & Ron Mar
[pdf / Adobe Acrobat Version]
Bulletin on Tax and Corporate Finance
Back-To-Back Loans and The 5/25 Withholding Tax Exemption - Kathleen Penny
Federal Court of Appeal and GAAR — Good News/Bad News - Doug Richardson & Wanda Rumball
“Green” Energy Projects - Bill Maclagan & Ron Richler
Draft Proposals on Interest Deductibility - Paul Tamaki
Joint Debt — A Matter of Form - Leslie Morgan
Applying the Transfer Pricing Rules to Guarantees - Janice McCart
[pdf / Adobe Acrobat Version]
Special Alert: The 2004 Federal Budget — Pensions Investing in Income Trusts
Special Alert: Mutual Fund Distributions to Non-Residents: 2004 Budget Changes
December 2003
New Case Law on Deductibility of Take-over Bid Costs
September 2003
Income Trusts — A Maturing Capital Market Sector
Restrictions on Non-Resident Ownership - Doug Richardson
Monitoring Non-Resident Ownership - Pat Finnerty
Legislative Initiatives to Limit Liability
of Trust Unitholders - Brendan
Reay & Dallas Droppo
Corporate Income Funds - Ron Richler
Spinning a U.S. Business Into a Canadian Income Trust - Leslie Morgan
Proposed Ontario Securities Commission Policy on Income Trusts - Ken Pearce
Investor Confidence Rules Raise Issues for Income Trusts - Jeff Lloyd
[pdf / Adobe Acrobat Version]
July 2003
Getting and Giving Third Party Taxpayer Information - Paul Tamaki
Claiming Privilege Against CCRA — The Good News and The Bad News from Recent Cases - Kathleen Penny
Foreign-based Information - Joel Shafer
Audit and Investigations - Limits from the Supreme Court of Canada - Paul Schabas
Solving Non-compliance Through Voluntary Disclosure - Bill
Maclagan
[pdf / Adobe Acrobat Version]
Focus on Taxation (2000 - 2002)
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