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The ability to borrow and lend securities without significant tax consequences is essential to various capital markets activities including repo financings and hedging the obligations created by certain derivative products. U.S.-based securities lenders have traditionally faced difficulties in lending to Canadian-based securities borrowers because of potential withholding tax on payments made as compensation for dividend or interest payments on the borrowed securities.

Are you thinking of incorporating your medical practice? As with any opportunity, there are risks and rewards to consider. Before making this decision, there are legal and tax implications you should be aware of.

Where there is a financing of a multinational group of affiliated corporations, it is becoming more common to have the indebtedness issued by several of the affiliated corporations as co-issuers, in which case there are various tax issues to address.

Earlier in 2019, the OECD published its Programme of Work to Develop a Consensus Solution to the Tax Challenges Arising from the Digitalization of the Economy (Program of Work), ...

Public Law no. 115-97 (2017 tax act)—the Tax Cuts and Jobs Act, signed December 22, 2017—significantly changed the Code and negatively affects a US person in Canada holding shares in a closely held corporation.

The 2015 federal Budget included a proposal to reduce the compliance burden of sending non-resident employees to work in Canada for short durations as of Jan. 1, 2016.

On June 7, 2017, Canada signed the OECD's Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI)...

Along with various COVID-19 relief programs introduced by the government, the CRA has announced policy changes to limit Canadian taxpayers and others experiencing unexpected changes to their taxes due to the pandemic.

Canada is one of the preferred locations for emigrating UK residents.

The Liberal government's second budget (Budget 2017) comes during a period of exceptional global political and economic uncertainty.

Canada and 67 other jurisdictions signed the OECD's Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting on June 7, 2017, at a signing ceremony in Paris.

The Technical Explanation (TE) provides commentary and some welcome clarification on the withholding tax exemptions to be provided by the Fifth Protocol (the Protocol) to the Canada-United States Income Tax Convention (the Treaty) on cross-border interest and guarantee fee payments, and the timing of this relief.

In this bulletin, we highlight two recent federal court cases in which U.S. taxpayers won major victories against the United States with respect to their obligations to report non-U.S. accounts...

With increasing frequency, Canadian corporations are venturing across the border into the United States to perform services or sell their products.

As many of our readers know, the Canadian Income Tax Act (the "Act") provides for an unlimited exemption from the imposition of Canadian income tax on the gains resulting from a disposition of a "principal residence".

There are two types of residence for taxpayers; their immigration residence and their tax residence. A taxpayer can be resident of one country for immigration purposes and resident of an entirely different country for tax purposes.

Canada can be a particularly lucrative market for international musicians looking to schedule concerts, tours and live performances.

In C & W Offshore Ltd. v. The King, the Tax Court of Canada held that a United Kingdom corporation (“InterMoor UK”) was the beneficial owner of rental payments...