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U.S. tax practitioners were the first to use hybrid instruments and entities in international tax planning.

Section 116 of the Income Tax Act (Canada) is a popular subject among tax commentators as it is fraught with pitfalls for the unwary.

All non-residents selling Canadian real estate are required to undergo the same process. Without proper guidance, it can be a long and complex process and can result in significant penalties.

Determining whether you are a resident of Canada for tax purposes is a critical first step in ensuring compliance with Canadian tax laws.

A high-net-worth individual (HWNI) is someone who possesses liquid assets totaling to at least $1 million after accounting for their liabilities.

Incoterms are an internationally recognized set of rules, published by the International Chamber of Commerce (the "ICC"), designed to allocate the risks, costs and tasks involved in business-to-business contracts for the sale of goods, and to settle on the place of legal delivery of such goods.

In a case argued in the Tax Court of Canada in September 2007 but not yet decided (Prevost Car Inc. v. The Queen, the Canada Revenue Agency (the CRA) has taken the position that a Netherlands holding company was not the “beneficial owner” of dividends paid to it by its Canadian subsidiary.

On April 1, 2021, the Canada Revenue Agency (CRA) released supplemental guidance on international income tax issues raised by the COVID-19 crisis.

Canada's Finance Minister announces proposed amendments to the Canada-U.S. Tax Convention and the federal Income Tax Act.

In the Canadian Federal Budget released on February 11, 2014, the Department of Finance signaled its intention to enact a domestic treaty-shopping rule, generally allowing the Canada Revenue Agency (CRA) to deny treaty benefits when the "main purpose" of a particular transaction is to obtain treaty benefits.

The Canadian government has proposed significant technical amendments to the Income Tax Act's definition of "taxable Canadian property" (TCP), fundamentally altering how publicly traded partnership units are classified and expanding the look-through rules for determining TCP status. These changes, effective upon Royal Assent, will impact cross-border transactions and investment structures by broadening the scope of what constitutes TCP and reinstating historical rules for options and interests in property.

It is trite law that one of the main purposes of tax treaties is to prevent double taxation of the same income.

Managing remotely raises unique tax issues for businesses.

Our firm, Moodys Tax Advisors, has proactively proposed legislation in Canada that will, if accepted and passed, allow a deduction against Canadian tax for the vast amount of professional fees paid to participate in the Internal Revenue Service's ("IRS's") 2011 Offshore Voluntary Disclosure Initiative ("OVDI"), the 2012 Offshore Voluntary Disclosure Program ("OVDP"), or the (traditional) Voluntary Disclosure procedure.

All non-residents selling Canadian real estate are required to undergo the same process. Without proper guidance, it can be a long and complex process and can result in significant penalties.

Doctors who are not practising through a health profession corporation may be missing out on some significant tax advantages and savings.

The Federal Court of Appeal ("FCA") judgment in eBay Canada Ltd. and eBay CS Vancouver Inc. v. M.N.R., 2008 FCA 348 ("eBay") is the latest in a series of decisions extending the power of the Minister of National Revenue ("Minister") to compel disclosure of confidential taxpayer information.