UK: Eclipse 35 Court Of Appeal Decision

The Eclipse 35 Court of Appeal decision leaves no doubt that where a tax avoidance scheme is found not to be trading by the Lower Courts, on appeal this will only be overturned in exceptional circumstances.

In seeking to alter behaviour, HMRC have found the perfect case, as participants in Eclipse not only failed to reduce their tax bill but now face catastrophically larger tax liabilities than if they had never participated in the scheme.

The […]

By |April 29th, 2015|

Canada: The Small Business Venture Capital Tax Credit Program In Manitoba – Are You Eligible?

The Small Business Venture Capital Tax Credit Program (“SBVCTC Program”) is established under The Income Tax Act (Manitoba) and the Small Business Venture Credit Tax Credit Regulation.

The SBVCTC Program is a very attractive, but under-utilized investment incentive program available in the Province of Manitoba to assist eligible small business corporations in raising capital and attracting new investors.
How it Works
Under the program, an “eligible corporation” may issue “eligible shares” to one or more “eligible investors”. […]

By |April 29th, 2015|

Canada: Charitable Gifts Involving Private Company Shares Or Real Estate

Earlier this week, the federal government released its 2015 budget. The budget contains a number of proposals to amend the Income Tax Act, and also provides updates regarding previously announced tax measures. One of the proposed changes announced in the budget will be especially relevant to donors and registered charities.

Currently, when capital property is donated to a registered charity, the donor is generally entitled to a donation tax credit (if the donor is an […]

By |April 28th, 2015|