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Copthorne Holdings Ltd V Canada
''Copthorne Holdings Ltd v Canada'', 2011 SCC 63, 0113 SCR 721, is a decision of the Supreme Court of Canada on the applicability of the General Anti-Avoidance Rule ("GAAR") in the interpretation of the '' Income Tax Act (Canada)''. ("ITA") The facts Copthorne Holdings was part of a group of Canadian and non-resident companies controlled by Li Ka-Shing and his son Victor Li. It had purchased the Harbour Castle Hilton hotel in Toronto in 1981, and sold it for a substantial capital gain in 1989. The proceeds of the sale had been invested by Copthorne in Copthorne Overseas Investment Ltd. ("COIL"), a wholly owned Barbados company that carried on an active bond-trading business in Singapore. Another company in the Li Group, VHHC Holdings, held directly (and indirectly through its subsidiary VHSUB Holdings) shares in Husky Energy Inc. By 1991, there was a substantial unrealized capital loss on that investment. In 1992, VHHC Holdings was sold to Copthorne, and VHHC Holdings subseque ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Supreme Court Of Canada
The Supreme Court of Canada (SCC; french: Cour suprême du Canada, CSC) is the Supreme court, highest court in the Court system of Canada, judicial system of Canada. It comprises List of Justices of the Supreme Court of Canada, nine justices, whose decisions are the ultimate application of Canadian law, and grants permission to between 40 and 75 litigants each year to appeal decisions rendered by provincial, territorial and federal Appeal, appellate courts. The Supreme Court is bijural, hearing cases from two major legal traditions (common law and Civil law (legal system), civil law) and bilingual, hearing cases in both Official bilingualism in Canada, official languages of Canada (English language, English and French language, French). The effects of any judicial decision on the common law, on the interpretation of statutes, or on any other application of law, can, in effect, be nullified by legislation, unless the particular decision of the court in question involves applicatio ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Financial Post
The ''Financial Post'' was an English Canadian business newspaper, which published from 1907 to 1998. In 1998, the publication was folded into the new ''National Post'',"Black says Post to merge with new paper". ''The Globe and Mail'', July 23, 1998. although the name ''Financial Post'' has been retained as the banner for that paper's business section and also lives on in the ''Post''s monthly business magazine, ''Financial Post Business''. The ''Financial Post'' started publication in 1907 by John Bayne Maclean."Publishing Inc. on the move". ''The Globe and Mail, April 9, 1983. It was a weekly publication, and one of the core assets of Maclean's media business, which eventually became Maclean-Hunter. The paper was purchased by Sun Media in 1987, and expanded into a daily tabloid on February 1, 1988, and added home delivery newspaper in 1990, with a reformatted ''Financial Post Magazine'' following shortly after. In 1998, Sun Media sold the ''Financial Post'' to Hollinger, whos ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Taxation In Canada
Taxation in Canada is a prerogative shared between the federal government and the various provincial and territorial legislatures. Legislation Under the ''Constitution Act, 1867'', taxation powers are vested in the Parliament of Canada under s. 91(3) for: The provincial legislatures have a more restricted authority under ss. 92(2) and 92(9) for: In turn, the provincial legislatures have authorized municipal councils to levy specific types of direct tax, such as property tax. The powers of taxation are circumscribed by ss. 53 and 54 (both extended to the provinces by s. 90), and 125, which state: Nature of the taxation power in Canada Since the 1930 Supreme Court of Canada ruling in ''Lawson v. Interior Tree Fruit and Vegetables Committee of Direction'', taxation is held to consist of the following characteristics: :* it is enforceable by law; :* imposed under the authority of the legislature; :* levied by a public body; and :* intended for a public purpose. In order ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Supreme Court Of Canada Cases
The Supreme Court of Canada is the court of last resort and final appeal in Canada. Cases that are successfully appealed to the Court are generally of national importance. Once a case is decided the Court will publish written reasons for the decision that consist of one or more reasons from any number of the nine justices. Understanding the background of the cases, their reasons and the authorship can be important and insightful as each judge may have varying beliefs in legal theory and understanding. List of cases by Court era * List of Supreme Court of Canada cases (Richards Court through Fauteux Court): This list includes cases from the formation of the Court on April 8, 1875, through to the retirement of Gérald Fauteux on December 23, 1973. * List of Supreme Court of Canada cases (Laskin Court): This list includes cases from the rise of Bora Laskin through to his death on March 26, 1984. * List of Supreme Court of Canada cases (Dickson Court): This list includes cases from t ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Ernst & Young
Ernst & Young Global Limited, trade name EY, is a multinational professional services partnership headquartered in London, England. EY is one of the largest professional services networks in the world. Along with Deloitte, KPMG and PricewaterhouseCoopers (PwC), it is considered one of the Big Four accounting firms. It primarily provides assurance (which includes financial audit), tax, consulting and advisory services to its clients. Like many of the larger accounting firms in recent years, EY has expanded into markets adjacent to accounting, including strategy, operations, HR, technology, and financial services consulting. EY operates as a network of member firms which are structured as separate legal entities in a partnership, which has 312,250 employees in over 700 offices in more than 150 countries around the world. The firm's current partnership was formed in 1989 by a merger of two accounting firms; Ernst & Whinney and Arthur Young & Co. It was named Ernst & Young until ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Canadian Tax Foundation
The Canadian Tax Foundation was founded in 1945 as an independent, non-partisan, non-profit tax research organization under the joint sponsorship of the Canadian Institute of Chartered Accountants and the Canadian Bar Association. It provides a unique forum for lawyers, accountants, academics, and other tax professionals to work together for the betterment of the Taxation in Canada, Canadian tax system and the tax profession in general. Information The Foundation is located in downtown Toronto, Ontario. In 1987, the Foundation's Quebec office was established in Montreal to serve the Quebec tax community in both official languages and to provide francophone practitioners across Canada with access in French to the Foundation's services. The Quebec office organizes conferences, seminars, and other professional-development events; maintains working relationships with tax authorities in Quebec and Ottawa; and represents the Foundation on various committees and working groups. The Canad ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Ratio Decidendi
''Ratio decidendi'' ( Latin plural ''rationes decidendi'') is a Latin phrase meaning "the reason" or "the rationale for the decision". The ''ratio decidendi'' is "the point in a case that determines the judgement" or "the principle that the case establishes".See Barron's Law Dictionary, page 385 (2d ed. 1984). In other words, ''ratio decidendi'' is a legal rule derived from, and consistent with, those parts of legal reasoning within a judgment on which the outcome of the case depends. It is a legal phrase which refers to the legal, moral, political and social principles used by a court to compose the rationale of a particular judgment. Unlike ''obiter dicta'', the ''ratio decidendi'' is, as a general rule, binding on courts of lower and later jurisdiction—through the doctrine of '' stare decisis''. Certain courts are able to overrule decisions of a court of coordinate jurisdiction. However, out of interests of judicial comity, they generally try to follow coordinate rationes. ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Obiter Dictum
''Obiter dictum'' (usually used in the plural, ''obiter dicta'') is a Latin phrase meaning "other things said",''Black's Law Dictionary'', p. 967 (5th ed. 1979). that is, a remark in a legal opinion that is "said in passing" by any judge or arbitrator. It is a concept derived from English common law, whereby a judgment comprises only two elements: ''ratio decidendi'' and ''obiter dicta''. For the purposes of judicial precedent, ''ratio decidendi'' is binding, whereas ''obiter dicta'' are persuasive only. Significance A judicial statement can be ''ratio decidendi'' only if it refers to the crucial facts and law of the case. Statements that are not crucial, or which refer to hypothetical facts or to unrelated law issues, are ''obiter dicta''. ''Obiter dicta'' (often simply ''dicta'', or ''obiter'') are remarks or observations made by a judge that, although included in the body of the court's opinion, do not form a necessary part of the court's decision. In a court opinion, ''obiter ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Marshall Rothstein
Marshall Rothstein (born December 25, 1940) is a former Puisne Justice of the Supreme Court of Canada. Early life Born in Winnipeg, Manitoba, to Jewish parents who immigrated from Eastern Europe, he received a Bachelor of Commerce in 1962 and an LL.B. in 1966 from the University of Manitoba. Marshall was the only child. His mother, a school teacher, was Russian and his father, a Pole, a bookkeeper and merchant. They met in Canada and settled in Winnipeg, where Marshall was born during the war years. Marshall's father wanted him to be an actuary, and so Marshall pursued a bachelor's degree in commerce at the University of Manitoba, but in his final year he took a course on commercial law and became fascinated by the law and decided on the law as a career path instead. Rothstein worked in food service on a passenger train while between semesters at university. The experience of being the lowest-ranked employee while interacting with a variety of people from different backgrounds ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
McCarthy Tétrault
McCarthy Tétrault LLP is a leading Canadian law firm that delivers integrated business law, litigation services, tax law, real property law, labour and employment law nationally and globally through offices in Vancouver, Calgary, Toronto, Montréal, Québec City, London (UK), as well as New York City. McCarthy Tétrault LLP is a Seven Sisters (law firms). Among the Seven Sisters, the reigning top players are McCarthy Tetrault LLP, Stikeman Elliott LLP, Osler Hoskin & Harcourt LLP and Blake Cassels & Graydon LLP. McCarthy Tétrault is the only law firm listed in the Report on Business Top 25 Best B2B Brands by ''The Globe and Mail'' in 2021, and it has the second strongest law firm brand in Canada according to ''Thomson Reuters’'' Regional Law Firm Brand Indexes 2021. The firm represents Canadian and international clients, including major public institutions, financial services organizations, mining companies, manufacturers, pharmaceutical companies and other corporations. ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Income Taxes In Canada
Income taxes in Canada constitute the majority of the annual revenues of the Government of Canada, and of the governments of the Provinces of Canada. In the fiscal year ending 31 March 2018, the federal government collected just over three times more revenue from personal income taxes than it did from corporate income taxes. Tax collection agreements enable different governments to levy taxes through a single administration and collection agency. The federal government collects personal income taxes on behalf of all provinces and territories. It also collects corporate income taxes on behalf of all provinces and territories except Alberta. Canada's federal income tax system is administered by the Canada Revenue Agency (CRA). Canadian federal income taxes, both personal and corporate are levied under the provisions of the ''Income Tax Act''. Provincial and territorial income taxes are levied under various provincial statutes. The Canadian income tax system is a self-assessment re ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Blake, Cassels & Graydon
Blake, Cassels & Graydon LLP (Blakes) is an international corporate law firm with offices in Montreal, Ottawa, Toronto, Calgary, Vancouver, New York City, and London. History Blakes was launched in 1856 after Dominick Edward Blake was called to the bar and entered into partnership with Stephen M. Jarvis in Toronto. Soon it was Blake & Blake when brother Samuel Hume Blake joined. In 1867, Blakes incorporated what would become Canadian Imperial Bank of Commerce. The bank remains one of the firm's oldest clients. In 1878, Blakes was the first business in Canada to install a telephone system that provided a direct link to the offices of the Ontario Court of Appeal and the Supreme Court of Canada at Osgoode Hall. In 1882, Zebulon Aiton Lash joined Blakes and began building a corporate law practice.Christopher Moore. The Law Society of Upper Canada and Ontario's Lawyers, 1797-1997'. University of Toronto Press; 1997. . p. 153–. By 1885, with 15 lawyers, Blakes was among the l ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
