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  • Article

    Treaty Shopping: MIL, MLI And ALTA Things In Between

    On February 12, the Federal Court of Appeal (FCA) released its decision in The Queen v. Alta Energy Luxembourg S.a.r.l.1 (Alta Energy),
    CanadaTax
    Torys
    Torys
  • Article

    When Your Employees Work In Canada: Income Tax Help For Non-Canadian Employers

    There are several tax issues to consider when employees work in Canada (temporarily or on a more permanent basis) for a foreign employer under the Income Tax Act (the Tax Act).
    CanadaTax
    Borden Ladner Gervais LLP
    Borden Ladner Gervais LLP
Article

Royal Bank Of Canada: A Common Sense Approach To Tax Treaty Interpretation

In Royal Bank of Canada v HMRC [2023] EWCA Civ 695, the Court of Appeal upheld the taxpayer's appeal in a case relating to the interpretation of the UK-Canada double tax treaty (the "Treaty").
GlobalTax
Herbert Smith Freehills Kramer LLP
Herbert Smith Freehills Kramer LLP
  • Article

    The World's First Carbon Border-adjusted Tax Enters Its Definitive Phase: What It Means For Canada

    On January 1, 2026, the European Union (EU) formally launched the world's first carbon border levy.
    GlobalTax
    Borden Ladner Gervais LLP
    Borden Ladner Gervais LLP
  • Article

    Canadian Olympic Athletes May Be Taxed In France & How International Athletes Are Taxed In Canada: A Canadian Lawyer Explains Tax Rules

    As the Paris Olympic ended in August 2024, tax experts from the UK warn that British athletes' gold medals could quickly lose their luster if participants unknowingly become liable for French taxes on income generated from the sport.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Important Income Tax Considerations For Foreign Residents Working In Canada

    For foreign residents who are physically working in Canada either permanently or temporarily, there are several Canadian tax issues to consider.
    CanadaTax
    Borden Ladner Gervais LLP
    Borden Ladner Gervais LLP
  • Article

    New Protocol To The Canada-U.S. Income Tax Convention Affects M&A Transactions

    The fifth protocol (Protocol) to the Canada-U.S. Income Tax Convention (Treaty) was signed on September 21, 2007. The Protocol contains the changes to the withholding tax rules for interest and the treatment of limited liability companies.
    CanadaTax
    Torys
    Torys
  • Article

    Treaty Shopping Proposals – A Review Of 2013 And 2014 Developments

    In Budget 2013, the Government announced its intention to consult on possible measures to combat treaty shopping.
    CanadaTax
    McCarthy Tétrault
    McCarthy Tétrault
  • Article

    CRA Reaffirms Withholding Taxes For Non-resident Contractors Under Regulation 105 And Its Recent Update: A Canadian Tax Lawyer Explains The Tax Rules

    Payments made to non-residents for services performed in Canada can carry significant tax consequences for both the payer and the service provider.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Income Tax For Canadians Working At Sea – A Canadian Tax Lawyer's Perspective

    If you are a Canadian citizen or resident working or planning to work at sea, then it may seem counterintuitive to learn that the income you earn from that job will be subject to Canadian income tax as though it was earned here in Canada.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Methanex Case And International 'Treaty Shopping' In Search Of Better Tax Breaks: Lessons For Canadian Corporations

    On April 22, 2025, the Judicial Committee of the UK Privy Council released its decision in Methanex Trinidad v. Board of Inland Revenue ([2025] UKPC 20).
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Tax Issues With Employees Working Remotely In Canada

    Remote work has become a new normal for many employees and employers, offering benefits to both parties. However, the prevalence of remote work has created new legal and regulatory challenges...
    CanadaTax
    Fasken
    Fasken
  • Article

    Tax Wars: It's Time To Think Strategically On International Tax Issues

    International tax issues and in particular transfer pricing, is often cited as the number one concern of businesses operating beyond their home border.
    CanadaTax
    Gowling WLG
    Gowling WLG
  • Article

    BEPS Final Reports: An Update On Treaty Shopping

    The Organisation for Economic Co-operation and Development (OECD) sees treaty shopping as an important source of Base Erosion and Profit Shifting.
    CanadaTax
    McCarthy Tétrault
    McCarthy Tétrault
  • Article

    Draft Regs For Novel Use Of TIEAs

    Last year, Canada's controversial 2007 spring budget effectively posted a notice to the tax havens of the world
    CanadaTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    Foreign Affiliate Proposals - Some Welcome And Unwelcome Changes

    On August 19, 2011, the Department of Finance (Finance) released extensive proposed amendments (2011 Proposals) to the foreign affiliate rules which, in some cases, replace a number of the more controversial amendments that were contained in the proposed amendments released on February 27, 2004 (2004 Proposals) and that may be viewed as a significant shift in tax policy.
    CanadaTax
    McCarthy Tétrault
    McCarthy Tétrault
  • Article

    Migrating IP Offshore Within A Transfer Pricing Setting

    If a multinational corporation had the luxury of perfect hindsight, it would optimize its global positioning and operational efficiencies by migrating intangible assets prior to those assets proving valuable.
    CanadaTax
    Gowling WLG
    Gowling WLG
  • Article

    Spinoff Techniques Revisited

    There has been a trend for a number of years for many public companies to seek to dispose of business operations that are outside of their core business or which otherwise are more appropriately owned by a separate public company, for example because their true value is not being reflected as part of a conglomerate.
    CanadaTax
    Fasken
    Fasken
  • Article

    Tax Court Affirms Treaty-Based Canadian Holding Structure

    The Tax Court of Canada recently held, in Alta Energy Luxembourg SARL v R, 2018 TCC 152, that a Luxembourg S.A.R.L was entitled to treaty benefits on capital gains...
    CanadaTax
    Bennett Jones LLP
    Bennett Jones LLP
  • Article

    Tax Letters: 2016 Canadian Federal Budget Commentary

    Finance Minister Bill Morneau delivered the 2016 Federal Budget on March 22, 2016.
    CanadaTax
    Crowe
    Crowe
  • Showing 281–300 of 543 results

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