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  • Article

    "Black Is The New Grey" – Treaty Interpretation In The Conrad Black Appeal

    Winston Churchill said there is "no such thing as a good tax" and thus it surely follows that no good can come from double taxation.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Canada Proposes Changes To Withholding Tax On Dividend Equivalent Payments

    The Canadian federal budget (Budget 2019) tabled on March 19, 2019 (Budget Day) contains important tax changes relevant to participants in the stock lending market
    CanadaTax
    Osler, Hoskin & Harcourt LLP
    Osler, Hoskin & Harcourt LLP
Article

Federal Court of Appeal Affirms Central Management & Control Test for Trust Residency

On November 17, 2010, the Federal Court of Appeal affirmed the landmark decision of the Tax Court of Canada in Garron and Garron, Trustees of the Garron Family Trust v. The Queen (reported as St. Michael Trust Corp.) and thereby ushered in new law on the question of trust residency.
CanadaTax
Aird & Berlis LLP
Aird & Berlis LLP
  • Article

    From Israel To Canada: New Tax Treaty To Help Structure Investments

    On December 21, 2016, the new Canada–Israel tax treaty entered into force.
    CanadaTax
    Blake, Cassels & Graydon LLP
    Blake, Cassels & Graydon LLP
  • Article

    Further Thoughts On The Fundy Settlement Decision: Supreme Court Offers A Nuanced View Of Trust Residence

    In "Garron Family Trust v. The Queen" (2009 TCC 450), Justice Judith Woods of the Tax Court of Canada came down with a very broad new rule for determining the residence of trusts.
    CanadaTax
    Dentons Canada LLP
    Dentons Canada LLP
  • Article

    Limited Liability Corporation

    Various tax efficient vehicles are available to Canadians who purchase and hold assets, or carry out business in the United States.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Tax 101: A Student's Handbook To Tax Literacy And Financial Responsibility

    Navigating the intricate realm of taxes can be intimidating for young adults and students in Canada. However, comprehending tax obligations...
    CanadaTax
    Rosen & Associates
    Rosen & Associates
  • Article

    Unsuccessful Crown Attempt To Apply GAAR To The Canada–Luxembourg Tax Treaty

    Taxpayers have greater certainty regarding their ability to enjoy the benefits of Canada’s tax treaties following the recent release of the Federal Court of Appeal decision in the case of "The Queen v. MIL (Investments) S.A."
    CanadaTax
    Blake, Cassels & Graydon LLP
    Blake, Cassels & Graydon LLP
  • Article

    Cross-Border Giving Update: Canadian Charities Cannot Use The Canada- US Tax Treaty To Fund American Charities Directly

    A major ruling from the Federal Court of Appeal (the "FCA") has sent a clear message to Canadian registered charities: The Canada-US Tax Treaty (the "Treaty") does not permit Canadian registered charities...
    GlobalCorporate/Commercial Law
    McCarthy Tétrault
    McCarthy Tétrault
  • Article

    Doing Business In Canada - September 2018

    Aird & Berlis is pleased to present the September 2018 edition of Doing Business in Canada. This publication was developed to provide a general overview of Canadian federal and Ontario law, and is intended for those planning to start, acquire or invest in a business in Canada.
    CanadaCorporate/Commercial Law
    Aird & Berlis LLP
    Aird & Berlis LLP
  • Article

    378 Days To Victory: The Conduct Of A Ground-Breaking Tax Treaty Case, Knights Of Columbus v. R.

    On Friday June 13, 2008, multinational enterprises doing business in Canada finally received greater tax certainty in respect of their cross-border operations.
    CanadaTax
    Dentons Canada LLP
    Dentons Canada LLP
  • Article

    Auston Matthews Shoots And Scores Tax Savings

    Fans of the Toronto Maple Leafs have reason to be thrilled today. Canadian taxpayers may have reason to be a bit irritated.
    CanadaTax
    Crowe Soberman LLP
    Crowe Soberman LLP
  • Article

    Canada's First Post-BEPS Tax Treaty: Implementing The New Treaty Shopping Proposals

    Last November, we told you about the new treaty shopping rules proposed by the OECD as part of the final report on Action 6 of the Action Plan on Base Erosion and Profit Shifting.
    CanadaTax
    Norton Rose Fulbright Canada LLP
    Norton Rose Fulbright Canada LLP
  • Article

    Canada And U.K. Agree To Protocol To Amend Tax Treaty

    On July 21, 2014, a protocol to amend the Canada-U.K. tax treaty was signed in London, England. Negotiations to update the Treaty had been ongoing since 2011.
    CanadaTax
    Blake, Cassels & Graydon LLP
    Blake, Cassels & Graydon LLP
  • Article

    International Retailers Continue To Come To Canada (Video)

    Canada's allure as a global luxury retail destination remains unwavering. With its stable political, economic and financial system...
    CanadaTax
    Osler, Hoskin & Harcourt LLP
    Osler, Hoskin & Harcourt LLP
  • Article

    More Cottage Life Tax Tips And Traps

    Thinking about putting that cottage up for sale? Plenty of people are thinking of cashing in, given the high demand – and commensurately higher prices – for out-of-town properties during the pandemic.
    CanadaTax
    Minden Gross LLP
    Minden Gross LLP
  • Article

    New Protocol To The Canada-U.S. Income Tax Convention

    The Honourable Jim Flaherty, Minister of Finance, and Henry M. Paulson, Jr., U.S. Secretary of the Treasury, have signed the Fifth Protocol (the “Protocol”) to the Canada-U.S. Tax Convention (the “Convention”) on September 21, 2007.
    CanadaTax
    Cassels
    Cassels
  • Article

    Tax Letters: 2016 Canadian Federal Budget – International

    In the domestic context, section 84.1 is designed to prevent surplus stripping in non-arm's-length situations. The following broad example illustrates this provision.
    CanadaTax
    Crowe
    Crowe
  • Article

    The Play Is Under Review: Maple Leafs Captain John Tavares Appealing CRA Reassessment

    Toronto Maple Leafs captain John Tavares is appealing the Canada Revenue Agency's reassessment of his 2018 income.
    CanadaTax
    Aird & Berlis LLP
    Aird & Berlis LLP
  • Article

    Transfer Pricing Audits: Exposures and Remedies

    Wthout proper policies and documentation in place, transfer pricing audits can result in long and costly corporate headaches.
    CanadaTax
    Crowe Soberman LLP
    Crowe Soberman LLP
  • Showing 121–140 of 543 results

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