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  • Article

    CRA Updates To COVID-19 Relief Guidelines And Travel Restrictions

    On April 1, 2021, the Canada Revenue Agency (CRA) updated its guidance and administrative relief relating to the impact of COVID-19 travel restrictions on residency and permanent establishment determinations.
    CanadaTax
    Borden Ladner Gervais LLP
    Borden Ladner Gervais LLP
  • Article

    Draft Foreign Affiliate Rules Include Significant Tax Policy Changes

    On August 19, 2011 the Department of Finance released proposed amendments to the Income Tax Act (Canada) related to the taxation of foreign affiliates of Canadian taxpayers.
    CanadaTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
Article

Taxation As A Cottage Industry

As the spring starts to ramp up and owners contemplate opening their cottages for the season, many decide to sell a recreational property instead of battling the mosquitoes.
CanadaTax
Minden Gross LLP
Minden Gross LLP
  • Article

    Doing Business In Canada

    Canada is known for its stable economy, skilled workforce, and business-friendly policies. Our team is committed to supporting your business journey and ensuring you have the tools and knowledge to thrive in the Canadian...
    CanadaCorporate/Commercial Law
    Osler, Hoskin & Harcourt LLP
    Osler, Hoskin & Harcourt LLP
  • Article

    Are You An "Accidental American"? Why Now May Be A Good Time To Renounce Your US Citizenship.

    An alarming number of people living abroad don't realize they're US citizens who are subject to annual taxation and filing obligations to the IRS.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Canada Begins Ratification Process For Multilateral Tax Convention To Implement BEPS

    The OECD's Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting [PDF] was tabled in the House of Commons on January 31, 2018.
    CanadaTax
    Osler, Hoskin & Harcourt LLP
    Osler, Hoskin & Harcourt LLP
  • Article

    Canadian Branch Profits Tax – Challenging The Denial Of Treaty-Benefits For US LLCS

    The Canada Revenue Agency continues to deny the benefits of the reduced "branch profits" tax rate.
    CanadaTax
    McMillan LLP
    McMillan LLP
  • Article

    Canadian SnowBirds Beware! 2014 Border Crossing Rules Increase Stakes For "Day Count"

    Virtually all Canadian snowbirds know they must keep track of how many days they are in the US and outside of Canada because "bad" tax and non-tax surprises await those who are in or out of either country too long.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Foreign Beneficiaries: From Multiple Taxation To Transfer Of Interests

    (May 8, 2019, 9:50 AM EDT) -- With increased mobility of people and their assets, more and more estates have a multijurisdictional dimension.
    CanadaTax
    O'Sullivan Estate Lawyers LLP
    O'Sullivan Estate Lawyers LLP
  • Article

    From Transfer Pricing To Tax Treaties: Canadian Cross-Border Tax Update

    The two most significant Canadian cross-border tax developments in 2018 relate to transfer pricing and tax treaties.
    CanadaTax
    Osler, Hoskin & Harcourt LLP
    Osler, Hoskin & Harcourt LLP
  • Article

    IRS Issues Broad Disclosure Rules For Foreign-Owned Disregarded U.S. Entities

    In the flood of guidance being issued in the waning days of the Obama Administration, the IRS and Treasury Department have finalized regulations that require foreign owners...
    CanadaTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    IRS Provides COVID-19 Relief For Stranded "Snowbirds" And Other International Travellers

    The emergence of COVID-19 in early 2020 has created significant global challenges, not the least of which include restrictions on the ability to travel between countries.
    CanadaTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    OECD Releases Discussion Draft On Tax Challenges Of The Digital Economy

    In July 2013, the Organisation for Economic Co-operation and Development released its Action Plan on Base Erosion and Profit Shifting.
    CanadaTax
    Osler, Hoskin & Harcourt LLP
    Osler, Hoskin & Harcourt LLP
  • Article

    OECD Releases Guidance For Pillar Two, Including GILTI Coexistence And QDMTT Design

    On February 2, 2023, the OECD/G20 Inclusive Framework on BEPS released Administrative Guidance on the GloBE Model Rules (Pillar Two) (Administrative Guidance).
    CanadaTax
    Osler, Hoskin & Harcourt LLP
    Osler, Hoskin & Harcourt LLP
  • Article

    Report Of The Advisory Panel On Canada´s System Of International Taxation

    On December 10, 2008 the Report (the "Report") of the Advisory Panel on Canada's System of International Taxation (the "Panel") was released.
    CanadaTax
    Gowling WLG
    Gowling WLG
  • Article

    Technical Explanation Clarifies Impact Of The Fifth Protocol On Employees

    Amendments to Article XV of the Canada-United States Income Tax Convention (the Treaty) appear to expand the circumstances in which Canada and the U.S. may tax each other’s residents who exercise employment in the other Contracting State.
    CanadaTax
    Blake, Cassels & Graydon LLP
    Blake, Cassels & Graydon LLP
  • Article

    Tax Treaty Residence Determination: Canadian Tax Lawyer Guide

    There are two factors that determine where a taxpayer pays taxes; where income is earned and where the taxpayer is tax resident.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    2010 Canadian Federal Budget Significantly Narrows Taxation Of Non- Residents Investing In Canadian Equity

    In its Budget delivered on March 4, 2010, the Government of Canada announced a significant liberalization of Canadian tax laws applicable to foreign investors in Canadian businesses.
    CanadaFinance and Banking
    Blake, Cassels & Graydon LLP
    Blake, Cassels & Graydon LLP
  • Article

    A Guide On Tax Residency Determination In Canada

    Under the Canadian taxation system, your income tax obligations and entitlements are informed by your residency status.
    CanadaTax
    Rosen & Associates
    Rosen & Associates
  • Article

    Application Of Treaty Benefits To Partnerships

    In Canada, dividends, interest, royalties and certain other payments paid to non-residents are subject to 25% withholding tax on the gross amount pursuant to the <I>Income Tax Act</I> (Canada) (the Act). Under most of Canada’s tax treaties, including the Canada-U.S. Tax Convention (the US Treaty) and the Canada-U.K. Tax Convention (the UK Treaty), the withholding rate is reduced on payments to persons who are residents of the U. S. or the U.K., respectively for purposes of the US Treaty or the U
    CanadaTax
    Blake, Cassels & Graydon LLP
    Blake, Cassels & Graydon LLP
  • Showing 181–200 of 543 results

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