Latest Briefings

Voluntary disclosures program update – The new normal

The Canada Revenue Agency voluntary disclosures program (VDP) has been around for decades. While the VDP has changed periodically, perhaps the most significant change occurred when the new Information Circular IC00-1R6, initially published on December 15, 2017, became effective on 1 March 2018.

Section 160 liability – Damis Properties Inc. v. The Queen

In Damis Properties Inc. v. The Queen, the Tax Court of Canada (TCC) found subsection 160(1) of the Income Tax Act inapplicable because the appellants and their former subsidiaries were dealing at arm’s length at the time of the transfer of the subject property. The TCC further concluded that, even if subsection 160(1) applied, the liability of the appellants under paragraph 160(1)(e) was nil because they gave fair market value consideration.

Private wealth – the potential for impact

“It is good to have money and the things money can buy, but its good too to check up once in a while and make sure you haven’t lost the things money can’t buy.” – George Lorimer

Nitrate neutrality

Developments on hold, trips to the High Court, nutrient credit schemes… Ever since a European Court of Justice ruling in November 2018, being nitrate neutral has caused headaches and blockages for developers and planners.

Bermuda: Three-day registration for special purpose insurers issuing bonds

Bermuda has always provided an efficient process for insurance submissions of all classes, with applications being approved in under two weeks. On 20 August 2021, the Bermuda Monetary Authority issued a notice announcing that enhancements have been made to allow further streamlining of the registration process for Restricted Special Purpose Insurers (“R-SPI”). Now, the licensing and registration processes of R-SPI registrants whose business model is to issue bonds (e.g. catastrophe bonds and mortgage bonds) will be consolidated and registrants can be fully registered within three business days.

Recommended

The deals that closed last week: Interserve-Mitie, Zopa and AllSaints

Calling upon Slaughter and May and Linklaters, Mitie and Interserve joined forces to gain scale in Britain’s expansive outsourcing industry. In a £271m deal, Mitie acquired the facilities management arm of rival Interserve, creating the UK’s largest facilities management business with 88,000 staff and a turnover of £3.5bn. The Goverment is currently relying heavily on […]

DWF Manchester

DWF to close two international offices in cost-cutting drive

DWF is to shut two of its international offices and downsize others, in a move that will see 60 people leave the business. The listed firm will be closing its outposts in Singapore and Brussels, reducing also the number of staff in Dubai and Cologne. As a result, around 60 individuals are expected to be […]

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