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Canada and the United States announced on February 5, 2014, that they had signed a long-awaited intergovernmental agreement (Canada–U.S. IGA) that dramatically expands the sharing of tax-related information between the countries.

On December 18, 2009, Canada’s Minister of Finance released draft regulations relating to the taxation of Canadian multinationals with foreign affiliates.

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting [PDF] – also known as the Multilateral Instrument or MLI – entered into force ...

In light of the COVID-19 crisis and the travel restrictions implemented by Canada and many other jurisdictions as well as by businesses.

Non-residents frequently invest in Canada through foreign intermediaries. A key consideration in structuring such investments is whether the intermediary will be subject to reduced rates of Canadian withholding tax in respect of payments received from Canadian parties.

The Canada Revenue Agency (CRA) recently indicated that Barbados "exempt insurance companies" (EICs) may be considered "liable to tax" in Barbados within the meaning of Article IV of the Canada-Barbados tax treaty.

In July 2013, the Organisation for Economic Co-operation and Development released its Action Plan on Base Erosion and Profit Shifting.

The Canada Revenue Agency ("CRA") recently issued the first Canadian Advance Income Tax Ruling ("ATR")[1] regarding whether a non-resident corporation ("NRco") has a permanent establishment ("PE") in Canada where part of its business activities have been sub-contracted to its wholly-owned subsidiary in Canada ("Canco") (the "Ruling").

On March 19, 2021, the Supreme Court of Canada heard the appeal in Canada v Alta Energy Luxembourg SARL, a case in which the Crown took the position that the taxpayer had engaged in abusive...

It is not uncommon for individuals to have more than one country in which they are considered a resident for tax purposes ("dual resident" or "dual residence").

Calgary is a growing and dynamic city that presents tremendous opportunity for businesses looking to expand. Historically known as an entrepreneurial oil and gas city, Calgary has embarked on a robust journey of economic diversification and is perfectly positioned for economic growth

Emigrating from Canada has a multitude of tax implications including which country can tax particular income and the Canadian tax owed for emigrating.

The minimum standard to address treaty abuse consists of two parts: (i) an amended preamble, suggesting that covered tax treaties are intended to eliminate double taxation...

As of June 30, 2026, Canada's administrative relief for Regulation 105 withholding requirements ends, requiring businesses to withhold 15% of fees paid to non-resident service providers for work performed in Canada. Understanding the application criteria, compliance obligations, and available waiver mechanisms becomes critical for businesses engaging non-resident contractors to avoid penalties and ensure proper tax remittance.

Are you a non-resident with a presence in Canada? A presence could be defined as employees, businesses, subsidiaries, investments or loans. If so, here are 10 tips and traps you should consider.

Tax season can be especially confusing for international students who are unfamiliar with Canada's taxation laws. One central question for international students is whether they need to file a Canadian tax return.

Every year, as June 15 rolls around, hundreds of thousands of Americans living abroad receive the same unwelcome reminder: it's time to file US taxes again.

When asking a U.S. tax adviser to describe the "revenue rule," it would not be surprising for the adviser to say that it refers to formal guidance issued by the I.R.S. that can be relied on by...