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On August 29, 2019, Canada completed its domestic ratification of the OECD-sponsored Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting

Join our panel of leading tax law experts as they examine some of the more contentious cross-border issues affecting foreign corporations doing business in Canada.

On May 29, 2019, Darcy Moch, Greg Johnson and Jared Mackey of Bennett Jones participated on a witness panel before the Standing Senate Committee

On July 29, 2008 the Fifth Protocol (the "Protocol") to the Canada-U.S. Tax Convention (the "Convention") was ordered to be reported "favorably" and "without amendment" out of the U.S. Senate Foreign Relations Committee.

We have been awaiting guidance from the IRS on the definition of property that will qualify as "good REIT assets" under the Internal Revenue Code.

The Minister of Finance for Canada - the Honourable James Flaherty - tabled the Conservative Government's federal Budget 2009 titled "Canada's Economic Action Plan" at 4:00 p.m. this afternoon.

International tax treaties generally tax income from business on a net basis. This contrasts with the taxation of investment income, which is taxed on a gross basis.

Under the US-Canada Income Tax Treaty, U.S. taxpayers who participate in Canadian registered retirement plans are not required to pay tax on the annual income and investment gains on their accounts.

Earlier in June 2017 68 members of the OECD signed a tax treaty that has the effect of amending bilateral tax treaties on a wholesale basis.

Last month, the Quebec government posted its budget for 2012-2013, which included a number of pension-related items.

One of the largest sources of work for our firm is from accounting and law firms who need specialized domestic and cross-border tax advice.

The MLI has been signed by 78 countries including Canada.

On January 16 and 17, 2017 CRA participated in a meeting of the Joint International Taskforce on Shared Intelligence and Collaboration Network (JITSIC), a network of over 35 tax administrations.

When software companies license or "sell" into Canada from abroad, there is often some leeway in how they allocate their fees between the license itself and related services.

On November 11, 2012, the Government of Canada signed a tax treaty with the Government of the Hong Kong Special Administrative Region of the People's Republic of China.

In the March 2013 Canadian federal budget, the Minister of Finance announced an intention to consult on possible measures to "protect the integrity of Canada's tax treaties while preserving a business tax environment that is conducive to foreign investment".

Canada and the U.S. executed a model 1 intergovernmental agreement which relieved Canadian financial institutions from many onerous obligations under FATCA.