Malta: Taxation Of A Securitisation Vehicle

Introduction
Securitisation was introduced in Malta’s legal framework in 2006 through the enactment of the Securitisation Act. New rules were then introduced in 2011 which provide rules regulating the taxation of income derived by a securitization vehicle together with the deductions which a securitization vehicle may be entitled to in terms of Malta’s income tax legislation.

A securitization transaction is a transaction whereby a securitization vehicle, directly or indirectly:

(a) acquires securitisation assets from an originator by […]

By |January 14th, 2015|

Canada: New Income Tax Folio – S6-F1-C1: Residence Of A Trust Or Estate

Effective September 19, 2014, the Canada Revenue Agency (the “CRA”) released a new Income Tax Folio on the Residence of a Trust or Estate. This Income Tax Folio (“S6-F1-CI”) replaces and cancels Interpretation Bulletin IT-447,Residence of a Trust or Estate. The purpose of S6-F1-CI is to provide CRA’s views concerning the determination of the residence status of a trust (as that term is defined in subsection 248(1) of the Income Tax Act, as amended […]

By |January 14th, 2015|

Canada: Professional Corporations For Physicians

Doctors who are not practising through a health profession corporation may be missing out on some significant tax advantages and savings. It has been about 8 years since the Ontario government changed some of the strict ownership rules that gave special treatment to professional corporations for doctors and dentists over other regulated health professions, operating their practices through a medicine professional corporation (“MPC”).

What is a professional corporation?

Similar to regular corporations, MPCs are distinct legal […]

By |January 13th, 2015|