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  • Article

    Remote Work Without Borders—But Not Necessarily Without Tax Consequences: OECD Guidance For A Post-Pandemic World

    Remote work is now a permanent feature of the global business landscape. Employees can perform their jobs from homes or holiday rentals located in entirely different countries from their employer's...
    CanadaEmployment and HR
    Bennett Jones LLP
    Bennett Jones LLP
  • Article

    So, An Employee Wants To Work Remotely In Canada, Eh?

    A number of issues can arise if an employee of a non-Canadian employer comes to Canada to work remotely. Unless the employee is seconded to a Canadian...
    CanadaEmployment and HR
    WeirFoulds LLP
WeirFoulds LLP
  • Article

    Business Measures In 2019 Federal Budget

    The 2019 Canadian federal budget was released on March 19, 2019.
    CanadaTax
    Bennett Jones LLP
    Bennett Jones LLP
  • Article

    Canada Ratifies The Multilateral Instrument

    On June 7, 2017, Canada along with numerous other jurisdictions signed the Organisation for Economic Co-operation and Development's
    CanadaTax
    McMillan LLP
    McMillan LLP
  • Article

    Canadian Challenge To FATCA

    In its 2015 budget, the federal government announced a commitment to implement the OECD's common reporting standards starting in July 2017 and reaffirmed Canada's commitment to introduce draft legislation in 2015.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    MLI Big Picture Changes Update

    Assuming the bill receives Royal Assent, Canada will then deposit a notice of ratification with the MLI depository
    CanadaTax
    McCarthy Tétrault
    McCarthy Tétrault
  • Article

    Tax Law Bulletin - New Protocol To The Canada-US Tax Treaty: Recognition Of LLCs And Elimination Of Treaty Benefits For Certain Hybrid Entities

    On September 21, 2007, Canada and the United States signed the long-awaited Fifth Protocol (the “Protocol”) to the Canada-US Income Tax Convention (the “Treaty”).
    CanadaTax
    McMillan LLP
    McMillan LLP
  • Article

    Taxation Of The Global Digital Economy

    Action 1 of the BEPS Project is focused on tax challenges associated with digitalisation.
    CanadaTax
    Fasken
    Fasken
  • Article

    Transfer Pricing: What's New In Canada (Part I)

    Since 2012, there have been unprecedented developments in Canada and globally in the area of international tax. The sheer volume and complexity
    CanadaTax
    Gowling WLG
    Gowling WLG
  • Article

    Moving South For The Winter? How That May Impact The Taxes You Owe

    As we move from warm cottage weather to the colder gusts of wind and eventual snowfalls that are non-negotiable staples of the Canadian climate...
    GlobalTax
    Devry Smith Frank LLP
    Devry Smith Frank LLP
  • Article

    OECD Considers Availability Of Tax Treaty Benefits For Investment Funds, Pension Funds And Private Equity Funds

    On November 21, 2014, as part of its Action Plan on Base Erosion and Profit Shifting (BEPS), the OECD released a discussion draft on "Follow-up work on BEPS Action 6: Preventing Treaty Abuse" (the Discussion Draft) for comments.
    CanadaFinance and Banking
    Osler, Hoskin & Harcourt LLP
    Osler, Hoskin & Harcourt LLP
  • Article

    Back-To-Back (B2B) Loans – Withholding Tax Rates On Interest, Rents, And Royalties

    For individuals or corporations that are not tax residents in Canada, certain payments that they receive from Canadian sources are subject to withholding taxes.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Canada Close To Ratifying The Multilateral Instrument

    Bill C-82, An Act to implement a multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting, has received royal assent.
    CanadaTax
    Torys
    Torys
  • Article

    The TaxLetter: Americans In Canada - U.S. Tax Issues

    What does it mean then if you are a U.S. citizen living in Canada? Even though you duly file your Canadian tax return and report all of your income, you are still required to file a U.S. tax return...
    CanadaTax
    Minden Gross LLP
    Minden Gross LLP
  • Article

    United States Permanent Establishment Enforcement And Expansion

    Recently, U.S. Internal Revenue Service (IRS) and Department of Treasury officials made statements expressing the increasing focus of U.S. enforcement activity and audit scrutiny on permanent establishment issues.
    CanadaTax
    Osler, Hoskin & Harcourt LLP
    Osler, Hoskin & Harcourt LLP
  • Article

    Alta Energy: Canada's Federal Court Of Appeal Rules That Treaty Shopping Is Not Abusive

    The Federal Court of Appeal in Alta Energy1 held that the Appellant, a Luxembourg corporation, could properly rely on the Canada-Luxembourg Treaty.
    CanadaTax
    Aird & Berlis LLP
    Aird & Berlis LLP
  • Article

    Canadian Snowbirds Should Know These US Tax Residence Rules – Tips from A Canadian Tax Lawyer

    If none of the factors are conclusive which is a very rare situation, you must ask the competent authority of each country to make a decision.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    COVID-19 Impact: New CRA Guidance On International Income Tax Issues

    On May 19, 2020, the Canada Revenue Agency (CRA) published guidance on the tax matters below relating to restrictions on travel (Travel Restrictions) because of the COVID-19 pandemic:
    CanadaTax
    Cassels
    Cassels
  • Article

    Supreme Court Releases Alta Energy Decision: Taxpayer Wins, Application Of GAAR To Tax Treaties Clarified

    On November 26, 2021, the Supreme Court of Canada released its decision in Alta Energy regarding the application of Canada's general anti-avoidance rule (GAAR) to tax treaties...
    CanadaTax
    Osler, Hoskin & Harcourt LLP
    Osler, Hoskin & Harcourt LLP
  • Article

    The Red Tape Reduction Trap: Cautions Against Removing Canadian Directors

    Cutting red tape has been a mantra of many governments at different levels and in a number of jurisdictions. The zeal with which it is professed to be done ...
    CanadaTax
    McLennan Ross LLP
    McLennan Ross LLP
  • Showing 261–280 of 543 results

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