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| Weekly Tax Highlights | ||
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. Visit our email subscription page to
subscribe to our publications, or to modify or cancel your subscription. Visit our Tax homepage to learn about our services. 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. |
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