Laurie A. Goldbach

Nov 10, 2023 | taxand.com | Laurie A. Goldbach

An analysis by Borden Ladner Gervais, Taxand CanadaEarlier this year, the Canadian government introduced Bill C-47, proposing amendments to the Income Tax Act including lower thresholds for reportable transactions, new reporting requirements for a (as yet undefined) category of ‘notifiable transactions’ and requirement for all advisors to file an information return for transactions.

Oct 12, 2023 | taxand.com | Laurie A. Goldbach

Analysis by Borden Ladner Gervais, Taxand CanadaOur Canadian firm analyses a recent ruling by the Tax Court of Canada in a case involving the Canada Revenue Agency (CRA) and a taxpayer. The CRA requested a tax planning document related to the hybrid sale prepared by the purchaser’s accounting firm. The taxpayer resisted, arguing the document’s irrelevance and citing the absence of an obligation to self-audit. The CRA, however, asserted that full disclosure of relevant documents was mandatory.

Oct 9, 2023 | canadian-accountant.com | Laurie A. Goldbach |Steve Suarez

Laurie Goldbach is a tax lawyer and partner in the Calgary office Borden Ladner Gervais LLP ("BLG"). Steve Suarez is a tax lawyer and partner in the Toronto office of BLG.

Sep 29, 2023 | mondaq.com | Laurie A. Goldbach |Steve Suarez

The recent Tax Court of Canada decision in Gaudreau v. The King demonstrates the ability of the Canada Revenue Agency (CRA) to obtain sensitive non-lawyer work product. In Gaudreau, the taxpayer was assessed under s. 84(2) of the Income Tax Act, (Tax Act) regarding their sale of an interest in an insurance company. The taxpayer vendor and the purchaser agreed on a hybrid sale, i.e., a sale of both assets and shares.

Aug 25, 2023 | taxand.com | Laurie A. Goldbach

An analysis by Borden Ladner Gervais, Taxand CanadaCanada has recently passed Bill C-47, a law that aims to enhance the transparency of tax-related activities. It introduces new rules regarding the disclosure of certain types of transactions to the Canada Revenue Agency (CRA). The bill includes a major expansion of the mandatory disclosure rules for “reportable transactions” and the introduction of disclosure requirements for “notifiable transactions”.