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A tax treaty is a bilateral agreement made by two countries to resolve certain tax issues such as double taxation, pension treatment or residence status determination for tax purposes.

If you are a Canadian planning to work abroad, you need to find out whether your residency will change, because if it does, it may affect your Canadian tax burden.

The Ontario Court of Appeal has released its much anticipated second decision in Third Eye Capital Corporation v. Ressources Dianor Inc./Dianor Resources Inc.

On August 12, 2013, Canada’s Department of Finance released a Consultation Paper on Treaty Shopping – The Problem and Possible Solutions.

On May 28, 2018, Canada introduced Bill C‑82 ( "Bill "), which, if passed, will bring into force the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion

Canada Revenue Agency levies income taxes on two bases. The first basis is on persons who have close ties to Canada – where such persons are residents of Canada.

The COVID-19 pandemic has resulted in the imposition of safety measures by governments around the world, including that in Canada, to protect the health of their citizens.

The Organisation for Economic Co-operation and Development (the OECD) recently published an update to its Model Tax Convention on Income and on Capital...

The long-awaited recent decision of the Federal Court of Appeal ("FCA") in "Prévost Car", 2009 FCA 57, upholds the principle that, in determining the applicable withholding rate on dividends, interest, royalties and other payments to treaty countries such as Holland, Luxembourg and other intermediary jurisdictions with low withholding tax rates, Canada Revenue Agency ("CRA") cannot ignore the intermediary jurisdiction and apply the higher rate that may be applicable had the payment been made dir

In Milgram Foundation v. Canada (Attorney General) (2024 FC 1405), the Federal Court of Canada held that the decision of the Canada Revenue Agency (CRA) to reassess after accepting the taxpayer's...

On October 27, 2017, under Bill C-63, the Department of Finance released proposed amendments to the Income Tax Act (Canada) ("ITA") introducing a new elective rule allowing non-residents tax-deferred ...

U.S. persons who are shareholders of Canadian corporations which are deemed controlled foreign corporations under the Internal Revenue Code will be subject to the transition tax as set out in section 965.

Taxation has become an increasingly global issue as people, money and property move freely across borders.

Treaty shopping has received a great deal of attention in Canada in recent years.

Under subsection 127(10.1) of the Income Tax Act (the Act), a Canadian-controlled private corporation (CCPC) may benefit from an additional 15% investment tax credit with respect to qualifying scientific research and experimental development expenditures.

A Tax Court judge ruled in favor of former Toronto Maple Leafs GM against the Canada Revenue Agency – guidance from a Canadian tax lawyer on special tax rules with professional athletes' contracts.

Moving to the United States may raise all sorts of concerns for individuals resident in Canada, not the least of which are the potential tax consequences to such a move.