Feb 3, 2010

Northwest Territories - 2010-2011 budget

On January 28, 2010, Finance Minister J. Michael Miltenberger presented the 2010-2011 budget to the Legislative Assembly of the Northwest Territories. In recognition of the fact that economic recovery will be slow, the budget included no new taxes. However, effective April 1, 2010, there will be policies in place to make adjustments to property tax rates, tobacco tax rates and liquor mark-ups to reflect inflation. For more information on the Northwest Territories budget, please refer to the Budget Address.

IRS announces proposal for reporting uncertain tax positions

On January 26, 2010, the United States Internal Revenue Service announced that it intends to require certain companies with assets in excess of $10 million to report their uncertain tax positions annually with their business tax returns. The proposed reporting requirement, as described in Announcement 2010-9, would apply to a taxpayer who prepares its own financial statements, or is part of the financial statements of a related entity that prepares financial statements, if the taxpayer or related entity determines its United States federal income tax reserves under FIN 48, or other accounting standards relating to uncertain tax positions involving United States federal income tax. The Service is asking business taxpayers and others to submit comments on the proposal by March 29, 2010.

Copthorne to be heard by SCC

On January 28, 2010, the Supreme Court of Canada granted leave to appeal Copthorne Holdings Ltd. This case involved the application of the general anti-avoidance rule (GAAR) on the basis that a tax benefit arose from the “inappropriate increase” in the paid-up capital of the taxpayer’s shares, which resulted from a series of transactions. Both the Tax Court of Canada and the Federal Court of Appeal (FCA) found in favour of the Minister of National Revenue and upheld the application of the GAAR and the resulting assessment of tax. The FCA decision can be referred to for more detailed information about the facts and issues of this case.

White House proposes $2.2 trillion tax hike for business, high-income individuals

President Barack Obama released a 10-year, $3.8 trillion FY 2011 budget proposal on February 1, 2010 that continues the populist tone he adopted in his recent State of the Union address and expands the tax principles he has espoused since the 2008 presidential election campaign: tax breaks for working families and small businesses, tax increases for upper-income individuals and corporations, reform of international tax rules, an end to tax preferences for large oil and gas companies, and closing of perceived corporate loopholes. In all, the budget package provides for $381 billion in tax relief and $2.2 trillion in revenue-raising provisions. For more information, read Deloitte’s Tax News & Views newsletter.

Budget dates

The federal government and the following provinces/territories have announced their 2010–2011 budget dates:

 

Upcoming:

Federal                             March 4, 2010

Alberta                             February 9, 2010

British Columbia                  March 2, 2010

Saskatchewan                    March 24, 2010

 

Tabled:

New Brunswick                   December 1, 2009

Northwest Territories          January 28, 2010

Deloitte’s global transfer pricing team ranked Number One

Deloitte has been named in Euromoney/Legal Media's 2009 Guide to the World's Leading Transfer Pricing Advisers, which recognized the firm as having the greatest number of leading transfer pricing advisers nominated. With 83 featured advisers, it is the fifth consecutive time that Deloitte has received the top ranking in this leading guide.

 

 

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This publication is produced by Deloitte & Touche LLP as an information service to clients and friends of the firm, and is not intended to substitute for competent professional advice. No action should be initiated without consulting your professional advisors. Your use of this document is at your own risk.