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With an increasingly global farm commodity market and a lower Canadian dollar, Canadian farmers are finding it much easier to sell their products in the United States.

Recent expectations about an announcement by the Internal Revenue Service (the "Service") that it would be providing broad relief to certain Canadians who failed to file foreign bank account reports ("FBARs") and U.S. tax returns appear to have been overly optimistic.

The ultimate tax liability of the employee will not be affected if the employee is not, in fact, entitled to treaty benefits in respect of the remuneration.

Canada's Phase 2 hybrid mismatch arrangement rules will deny deductions on a far broader set of cross-border payments starting July 1, 2026, particularly affecting structures with Canadian unlimited liability companies or partnerships treated as corporations for US tax purposes.

In what's becoming our firm's annual tradition, the purpose of this blog is to gaze into the crystal ball to predict what the tax goodies might look like when the 2016 federal budget is released.

Canadian tax rules require ALL EMPLOYERS to withhold Canadian income tax from remuneration paid to employees providing services in Canada per Regulation 102 (Reg. 102).

In Her Majesty the Queen v. Alta Energy Luxembourg S.A.R.L., the Federal Court of Appeal confirmed that so-called "treaty shopping" is not abusive of Canada's tax treaties.

In a recent decision, the Tax Court of Canada considered CRA's own prior statements as well as the commercial realities of resource companies in finding that treaty benefits applied to a Luxembourg corporation.

COVID-19 has, and will continue to, disrupt historical revenue and cash management of many multi-national corporate groups.

At yesterday's Canada Revenue Agency ("CRA") round table, held as part of the Canadian Tax Foundation's annual conference in Toronto, the CRA provided its views with respect to a number of topics including, among other things, branch tax implications when investing in Canada through a U.S. limited liability company (including where a U.S. resident individual is a member), Canadian permanent establishment implications where an employee of a U.S. resident provides services in Canada, the tax conse

G7 Finance Ministers, including Minister Chrystia Freeland from Canada, commit to the principal design elements for Pillar One and Pillar Two.

The COVID-19 pandemic has resulted in the imposition of travel restrictions by governments and businesses.

On May 16, 2008, two significant decisions of the Tax Court of Canada (the Court) dealing with the interpretation of the meaning of permanent establish¬ment under the Canada–United States Tax Convention (the Convention) were released: “Knights of Columbus v. R., and American Income Life Insurance Company v. R.”.

Revisions have been announced to the IRS’s relatively new program known as Pre-Filing Agreements, which provide potentially important benefits to foreign companies.

On August 22, 2018, the Tax Court of Canada released its decision in the Alta Energy case.

In the recently released Budget 2021, Canada's federal government announced its plan to continue with the development of a Digital Services Tax (DST) to be imposed on certain large taxpayers.

The captain of the Toronto Maple Leafs (the "Leafs"), John Tavares ("Tavares"), is currently in the process of appealing a Notice of Reassessment that was issued by the Canada Revenue Agency ("CRA")...