543 results found

I recently attended the annual National Business Aviation Association conference where I had the opportunity to catch up with my non-Canadian contacts in business aviation.

The COVID-19 crisis has led to travel restrictions that have required many people to work remotely, and sometimes to remain in jurisdictions other than those in which...

On October 17, 2009, the Government of Québec announced that it intends to tackle the issue of aggressive tax planning through the implementation of measures targeting its disclosure and through clarifications to the notion of bona fide purpose in the context of the application of the general anti-avoidance rule (GAAR).

Canada and the UK signed the fourth protocol amending the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland.

The Canadian government's suite of refundable clean economy investment tax credits (ITCs) represents a shift in how large-scale decarbonization projects in Canada will be financed.

Under the Canada-U.S. Income Tax Convention (the "Treaty"), a corporation resident in the United States may be taxed in Canada where its activities give rise to a "permanent establishment".

There are two types of individuals who must pay tax in Canada – Canadian residents and non-residents.

The Patient Protection and Affordable Care Act of 2010 included new section 1411, which imposes a 3.8 percent tax on net investment income on U.S.

Where a taxpayer considers that the assessing actions of one of the Contracting States to the Canada-U.S. Income Tax Convention (the Treaty) will result in double taxation, the taxpayer may present its case to the competent authority of the Contracting State of which the taxpayer is a resident.

The United States' One Big Beautiful Bill (OBBB), signed into law in 2025, represents a sweeping tax overhaul for individuals and corporations.

Canada and the United States signed the widely anticipated 5th protocol to the Canada-U.S. Tax Treaty today. Once it has been ratified by both countries, the Protocol will ultimately eliminate withholding tax on conventional interest payments made by Canadian taxpayers to U.S. residents.

Following-up on certain policy statements contained in last year's federal budget, along with a consultation paper (the "Consultation Paper") released this past August ..

At the April 2017 International Tax Conference of the International Fiscal Association Canada, a representative of the Department of Finance ("Finance") again confirmed that it is Canada's intention...

Taxpayers can easily make mistakes navigating a transfer pricing dispute without strategically considering the choices of pursuing domestic avenues for relief or pursuing treaty-based avenues...

On May 31, 2019, as one of the main areas of focus of the ongoing work on the Base Erosion and Profit Shifting ("BEPS") project, Members of the OECD/G20 Inclusive Framework on BEPS ("Framework")

On November 26, 2021, the Supreme Court of Canada (the SCC) released its highly anticipated decision in Canada v Alta Energy Luxembourg SARL, 2021 SCC 49 [Alta Energy Lux],...

To many people, an unlimited liability company (ULC) may sound like a contradiction in terms.