Redeemable preferred shares issued in a tax planning arrangement

Raymond Chabot Grant Thornton has just published the November 2014 Flash Bulletin, titled “Redeemable preferred shares issued in a tax planning arrangement (Exposure Draft issued)”. In this edition, we have outlined the most significant proposed modifications by the AcSB in its Exposure Draft “Redeemable preferred shares issued in a tax planning arrangement”.


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In general, a person carrying on a business is required to collect and remit GST and QST to the government. However, for the purposes of the Excise Tax Act (ETA) and An Act respecting the Québec sales tax (AQST), a joint venture is not a person. Consequently, each co-venturer is required to collect and remit tax and claim tax credits on its share of supplies carried out through the joint venture. The accounting treatment of these transactions may be complex and may not reflect the business reality. For this reason, the participants in a joint venture may elect to have one of the co-venturers (called “operator”) handle all the GST/HST/QST accounting.

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What this means for the retail industry

September 2014

The International Accounting Standards Board (IASB) and U.S. Financial Accounting Standards Board have finally issued their new standard on revenue – IFRS 15 Revenue from Contracts with Customers (ASU 2014-09 or Topic 606 in the U.S.). This bulletin summarizes the new requirements and what they will mean for entities in the retail industry that apply International Financial Reporting Standards (IFRS).

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The Organisation for Economic Co-operation and Development (“OECD”) presented in a September 16, 2014 webcast its first set of deliverables following its Action Plan to address Base Erosion and Profit Shifting (“BEPS”). BEPS refers to the reduction in governments’ tax revenues resulting from the erosion of their tax base, particularly through the shifting of profits by multinational corporations to low-tax or no-tax jurisdictions. Two of these BEPS deliverables address transfer pricing, namely, the transfer pricing of intangibles, and transfer pricing documentation together with country by country reporting.

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