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  • Article

    Anti-Treaty Shopping Proposals – Will Canada Be Violating Its Tax Treaties? (CCH Online)

    Ken Snider authored the article "Anti-Treaty Shopping Proposals - Will Canada be Violating its Tax Treaties?"
    CanadaTax
    Cassels
    Cassels
  • Article

    End Of The "Address Rule" For Determining Withholding On Payments To Non-Residents — Extension Of Transitional Period Announced

    In our earlier update, "New Developments in Canadian Withholding Tax Obligations — New Forms Signal the End of the "Address Rule"," we discussed the change from the Canada Revenue Agency's previous position that generally accepted the use of the payee's name and address for determining whether to apply treaty benefits
    CanadaTax
    McCarthy Tétrault
McCarthy Tétrault
  • Article

    Federal Budget 2017 Tax Highlights

    On March 22, 2017, Finance Minister Bill Morneau will table the second federal budget ("Budget 2017") of the Justin Trudeau-led Liberals and the Crowe Soberman Tax Team will be in Ottawa participating in the Secured Reading for Tax Practitioners
    CanadaTax
    Crowe Soberman LLP
    Crowe Soberman LLP
  • Article

    Supreme Court Of Canada Dismisses Leave To Appeal In Prescient Foundation

    The application for leave to appeal the Federal Court of Appeal’s decision in Prescient Foundation v Minister of National Revenue was dismissed by the Supreme Court of Canada ("SCC") with costs on November 28, 2013.
    CanadaTax
    Borden Ladner Gervais LLP
    Borden Ladner Gervais LLP
  • Article

    Canada Reviews International Tax System

    On April 25, 2008, the Advisory Panel established by the Canadian Government following on the 2007 Budget initiative to study Canada’s international tax system and make recommendations for change, issued its first report in the form of a Consultation Paper entitled "Enhancing Canada’s International Tax Advantage.
    CanadaTax
    Borden Ladner Gervais LLP
    Borden Ladner Gervais LLP
  • Article

    BEPS Targets Commonly Used Canada-U.S. Hybrid Structures

    Davies Partner Abraham Leitner discusses the impact of the OECD’s recommendations on a number of structures commonly seen in Canada-U.S. cross-border financings.
    CanadaTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    Canada And The U.S. Enter Into FATCA Intergovernmental Agreement

    The U.S. Treasury Department and the Canadian government both announced today that Canada and the United States have signed an intergovernmental agreement to implement the provisions of FATCA.
    CanadaTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    Canada And The U.S. Sign FATCA Agreement

    On February 5, 2014, the Department of Finance announced that Canada and the United States have reached an agreement to address the application of the U.S. Foreign Account Tax Compliance Act (FATCA) in Canada.
    CanadaTax
    Stikeman Elliott LLP
    Stikeman Elliott LLP
  • Article

    FATCA Intergovernmental Agreement With Canada Is In The Works

    The Canadian Department of Finance announced on November 8th that negotiations are being held between Canada and the United States on an agreement to improve cross-border tax compliance.
    CanadaTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    Taxation Of Cryptocurrencies & Tokens (Part II) — Forking-Up Taxes On Forks?

    As the looming threat of cryptocurrency regulation in the area of securities continues to monopolize the public limelight, little attention by Canadian governmental authorities is being given to the taxation of transactions involving tokens.
    CanadaTechnology
    Miller Thomson
    Miller Thomson
  • Article

    2016 Canadian Federal Budget Highlights

    Finance Minister Bill Morneau delivered the 2016 Federal Budget on March 22, 2016. The Crowe MacKay Tax Team has summarized the highlights here.
    CanadaTax
    Crowe
    Crowe
  • Article

    Budget Briefing 2016

    The Honourable Bill Morneau, Minister of Finance, tabled the Liberal government's first budget on March 22, 2016 (Budget 2016).
    CanadaTax
    Osler, Hoskin & Harcourt LLP
    Osler, Hoskin & Harcourt LLP
  • Article

    Canada – Switzerland Bank Information Exchange

    The Swiss Consulate in Canada has been writing to Swiss residents of Canada to advise them of the information exchange agreement between Canada and Switzerland.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Canada Repeals Withholding Tax

    The legislation to eliminate Canadian withholding tax on interest paid by Canadian residents to arm’s-length, unrelated non-residents has been enacted and is now in force.
    CanadaTax
    Blake, Cassels & Graydon LLP
    Blake, Cassels & Graydon LLP
  • Article

    Canada To Amend DTAs With Germany, Switzerland

    The Canadian Government has announced its intention to update its double tax agreements (DTAs) with Germany and Switzerland.
    CanadaTax
    CLD Legal
    CLD Legal
  • Article

    Canadá modifica DTA con Alemania, Suiza

    El Gobierno de Canadá ha anunciado su intención de actualizar sus acuerdos de doble imposición (DTA) con Alemania y Suiza.
    CanadaTax
    CLD Legal
    CLD Legal
  • Article

    Constitutional Challenge Of FATCA Agreement Launched

    On August 11, a constitutional challenge to the new FATCA provisions contained in Part XVIII of the Income Tax Act (Canada) was filed in Federal Court in Vancouver.
    CanadaTax
    Stikeman Elliott LLP
    Stikeman Elliott LLP
  • Article

    Draft And Recently-Enacted Amendments Impact Canadian Outbound Investment Tax Rules

    On December 18, 2009, the Canadian Department of Finance (Finance) released a package of proposed foreign affiliate amendments (the 2009 Proposals).
    CanadaTax
    Osler, Hoskin & Harcourt LLP
    Osler, Hoskin & Harcourt LLP
  • Article

    FATCA Regulations Create Deemed Compliant FI Category

    The Internal Revenue Service and the U.S. Treasury Department recently released amendments to the final FATCA regulations, in part so as to provide better coordination with the intergovernmental agreements.
    CanadaTax
    Stikeman Elliott LLP
    Stikeman Elliott LLP
  • Article

    Federal Budget Proposals Signal Possible Change Of Course On International Tax Issues

    This year's Federal Budget focuses on fiscal stimulation with significant spending measures. It also contains a number of noteworthy income tax proposals.
    CanadaTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Showing 1–20 of 543 results

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