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The primary sources of Canadian tax law are (i) the legislation from federal Parliament, composed principally of the Income Tax Act the Excise Tax Act...

we discussed the immigration impacts of recent border closures and travel restrictions due to the COVID-19 pandemic for snowbirds and those on B-1 (business visitors) and B-2 (visitors for pleasure)

This article updates developments relating to the Multilateral Convention to implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) ...

The Canada Revenue Agency ("CRA") has been steadily increasing the intensity of audits targeting cross-border investment and business activity.

By way of background, the "Fifth Protocol" is a protocol to amend the Canada-U.S. Tax Convention (the "Treaty").

The Department of Finance announced in the federal budget of March 4, 2010, a proposed legislation regarding FTC generators and released modified draft legislation on August 27, 2010.

The Fifth Protocol (the “Protocol”) to the Canada-US Income Tax Convention (the “Treaty”) introduces significant changes to the rules relating to corporate continuance and residence.

The recently released Fifth Protocol (the “Protocol”) to the Canada-US Income Tax Convention (the “Treaty”) significantly expands the scope of the Treaty provisions dealing with pensions.

Section 261 of Income Tax Act generally requires amounts reported on Canadian tax returns and other tax filings be reported in Canadian currency.

On July 11, 2023, the OECD/G20 Inclusive Framework on BEPS approved a four-part Outcome Statement on the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation...

Canada has over 90 bilateral tax treaties and over 20 bilateral Tax Information Exchange Agreements in force, with at least a dozen more treaties or agreements in the negotiation stage.

As discussed in our April 2015 article Welcome changes for non-resident employees working in Canada, the 2015 federal budget proposed changes to alleviate the administrative burden relating to withholding tax regulations on non-resident employees working in Canada.

COVID-19 has resulted in Canada and other governments around the world imposing restrictions on international travel ("Travel Restrictions").

The determination of whether a permanent establishment (PE) exists in Canada has always been the subject of confusion and uncertainty for non-resident taxpayers doing business or contemplating doing business in Canada.

The Canada Revenue Agency (CRA) recently released its 2012 annual report on the Canadian Mutual Agreement Procedure (MAP) program – the CRA’s mandatory service program designed to help taxpayers resolve cases of:

Four bounces off the rim… and in! A thundering slam dunk over the presumptive NBA MVP. Nailing two free throws in the final 0.9 seconds—sealing the first ever NBA Championship for the Toronto Raptors.

A nine-page framework (the Unified Framework for Fixing Our Broken Tax Code [PDF]) was released on Wednesday, September 27, by the "Big Six" group of Republican Congressional leaders...