LIVE Evacuation order issued for some Fort McMurray neighbourhoods as wildfire nears
Four Fort McMurray neighbourhoods were ordered to evacuate as a wildfire gets closer to the city.
Loblaw Financial Holdings should not have to pay Canadian taxes on income from a subsidiary the company ran in Barbados, the Supreme Court of Canada has ruled.
In a 7-0 decision Friday, the top court said Canadian provisions at issue in the case do not apply to the subsidiary, Glenhuron Bank, meaning tax on its income is not payable in Canada.
Loblaw Financial, part of a larger group that includes the well-known grocery retailer, incorporated the subsidiary in 1992. Barbados' central bank issued a licence for it to operate as an offshore bank.
In 2013, Glenhuron was dissolved, and its assets were liquidated to help Loblaw buy Shoppers Drug Mart.
Loblaw Financial and affiliated companies made capital investments in Glenhuron, which engaged in corporate banking, between 1992 and 2000.
For several taxation years from 2001 and 2010, Loblaw Financial did not include income earned by Glenhuron in its Canadian tax returns as foreign accrual property income, known as FAPI.
The federal revenue minister issued reassessments to Loblaw Financial that required it to pay tax on Glenhuron's income on the grounds it fell under the provisions.
The federal Tax Court agreed with the minister in 2018 that Glenhuron's income did not qualify for an exclusion afforded to foreign banks.
The court concluded that Glenhuron conducted business principally with affiliated corporations, not parties with whom it was dealing at arm's length, as required by the legislation.
The Federal Court of Appeal overturned the decision, referring the reassessments back to the minister for reconsideration. The Crown then took its case to the Supreme Court.
In its unanimous decision, the top court found the vast majority of business was conducted between Loblaw Financial's foreign affiliate and arm's-length parties, so the exception in the law did in fact apply.
A parent corporation does not conduct business with its foreign affiliate when it provides capital and exercises corporate oversight, the Supreme Court said.
On the arm's-length side, Glenhuron invested in short-term debt securities, cross-currency swaps and interest swaps, Justice Suzanne Cote wrote on behalf of the court.
"These were by far the most lucrative activities undertaken by Glenhuron, amounting to at least 86 per cent of its income during the years in issue."
This report by The Canadian Press was first published Dec. 3, 2021.
Four Fort McMurray neighbourhoods were ordered to evacuate as a wildfire gets closer to the city.
Canadian LifeLabs customers who filed an application for a class-action settlement began receiving their payments this week, though at a much lower amount than initially expected.
Nobel laureate Alice Munro, the Canadian literary giant who became one of the world's most esteemed contemporary authors and one of history's most honoured short story writers, has died at age 92.
The doctor who led Toronto through the COVID-19 pandemic as the city’s top public health official is stepping down.
Wildfires have led Environment Canada to issue air quality advisories for parts of B.C., Alberta, Manitoba, Saskatchewan and the Northwest Territories, as forecasters warn the smoke could drift farther east.
Saskatchewan RCMP have revealed that a historic sexual assault investigation has led to the discovery of alleged crimes against children dating back to 2005.
An American accused of sexually assaulting a Pennsylvania college student in 2013 and later sending her a Facebook message that said, 'So I raped you,' has been detained in France after a three-year search.
The annual list of Canada's top restaurants in the country was just released and here are the places that made the 2024 cut.
Ontario Provincial Police are responding to a fatal collision involving two vehicles on Highway 417 in Ottawa's west end on Tuesday morning.
A team is ready to help an entangled North Atlantic right whale in the Gulf of St. Lawrence.
A $200 reward is being offered by a North Vancouver family for the safe return of their beloved chicken, Snowflake.
Two daughters and a mother were reunited online 40 years later thanks to a DNA kit and a Zoom connection despite living on three separate continents and speaking different languages.
Mother's Day can be a difficult occasion for those who have lost or are estranged from their mom.
YES Theatre Young Company opened its acclaimed kids’ show, One Small Step, at Sudbury Theatre Centre on Saturday.
An Ottawa pizzeria is being recognized as one of the top 20 deep-dish pizzas in the world.
A family of fifth generation farmers from Ituna, Sask. are trying to find answers after discovering several strange objects lying on their land.
A Listowel, Ont. man, drafted by the Hamilton Tigercats last week, is also getting looks from the NFL, despite only playing 27 games of football in his life.
The threat of zebra mussels has prompted the federal government to temporarily ban watercraft from a Manitoba lake popular with tourists.