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  • Article

    Guide To The Canadian Tax Treatment Of Halal Mortgages: Halal Mortgages Are Shari'ah-Compliant But Taxable In Canada

    If you are a Muslim homebuyer weighing a halal mortgage against a conventional one, the product that keeps you offside your faith may still put you offside the taxman in ways a conventional mortgage never would.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Release Of The Federal Budget, 2021

    On Monday, April 19, 2021, Canada's Deputy Prime Minister and Minister of Finance, Chrystia Freeland, released the first official budget in the past two years...
    CanadaTax
    Dickinson Wright PLLC
    Dickinson Wright PLLC
Article

The Competent Authority Process: 2026 Transfer Pricing Guide – Part 4

Canadian taxpayers facing cross-border tax disputes have access to several treaty-based relief mechanisms, including the Mutual Agreement Procedure (MAP), Accelerated Competent Authority Procedure (ACAP), and Advance Pricing Arrangements (APA). When competent authorities cannot reach agreement, mandatory binding arbitration may be available under certain tax treaties to resolve double taxation issues and ensure consistent treatment across jurisdictions.
CanadaTax
McCarthy Tétrault
McCarthy Tétrault
  • Article

    2021 Federal Budget – Selected Tax Measures

    More than two years after the last federal budget, Canada's Finance Minister presented the 2021 budget (Budget 2021) on April 19, 2021 (Budget Day). Some commentators speculated that Budget 2021
    CanadaTax
    Blake, Cassels & Graydon LLP
    Blake, Cassels & Graydon LLP
  • Article

    Pension Law Regulatory Update and New Case Developments

    In 2005, the law on pensions and employee benefits has continued to see significant changes implemented or proposed. Here are some of the most recent pension and benefits cases, as well as developments in Canadian legislative and regulatory policy.
    CanadaEmployment and HR
    Blake, Cassels & Graydon LLP
    Blake, Cassels & Graydon LLP
  • Article

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

    In Parts I and II of this article, we provided an overview of transfer pricing developments and jurisprudence, respectively, in Canada since the start of the Organization for Economic Cooperation
    CanadaTax
    Gowling WLG
    Gowling WLG
  • Article

    Canadian Tax Laws: A Review Of 2019 And A Look Ahead To 2020

    With the October federal election looming, 2019 was a relatively quiet year for tax legislation.
    CanadaTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    The Sifto Decision — Is The Minister Bound By MAP Settlements?

    On March 10, 2017, the Tax Court of Canada ("TCC") delivered its decision in Sifto Canada Corp. v. The Queen1 regarding the legal effect of a transfer pricing settlement reached under the Mutual Agreement...
    CanadaTax
    Gowling WLG
    Gowling WLG
  • Article

    The Supreme Court Of Canada Clarifies The Jurisdiction Between The Tax Court Of Canada And The Federal Court

    On June 28, 2024, the Supreme Court of Canada released its long-anticipated companion decisions in Dow Chemical Canada ULC v. Canada...
    CanadaTax
    McCarthy Tétrault
    McCarthy Tétrault
  • Article

    Budget 2012 - Canada

    The Canadian Government introduced its budget today ("Budget 2012") announcing a number of significant tax measures. The following is a brief summary of these measures, many of which come into effect today (the "Budget Day").
    CanadaTax
    Fasken
    Fasken
  • Article

    Canadian Income Tax: What Foreign Companies Need To Assess About Canadian Taxes

    Foreign companies entering Canada face a complex tax landscape where home-country assumptions about deductibility, intercompany charges, and holding structures often don't apply.
    CanadaTax
    Miller Thomson
    Miller Thomson
  • Article

    The BEPS Deliverables: A Macro Critique

    The OECD's crusade against base erosion and profit shifting will be remembered either as a well-coordinated campaign against abusive tax avoidance, or a waste of vast amounts of time and resources.
    CanadaTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    The First Five FCA Tax Decisions Of 2026

    In an eventful start to 2026, the Federal Court of Appeal (FCA) has already released five notable tax decisions. Signalling an active and consequential year ahead...
    CanadaTax
    Blake, Cassels & Graydon LLP
    Blake, Cassels & Graydon LLP
  • Article

    The Transfer Pricing Audit: 2026 Transfer Pricing Guide – Part 2

    Navigate the complexities of Canadian transfer pricing audits with expert guidance on documentation requirements, CRA audit powers, and privilege protection. Learn strategic approaches to functional interviews, information requests, and compliance obligations while understanding the consequences of non-compliance and proposed legislative changes that could significantly impact audit procedures.
    CanadaTax
    McCarthy Tétrault
    McCarthy Tétrault
  • Article

    Key Tax Measures In The 2023 Fall Economic Statement

    On November 21, 2023, the Minister of Finance (Minister) released Canada's 2023 Fall Economic Statement (FES). The primary focus of the FES is on affordability measures for Canadians...
    CanadaTax
    Blake, Cassels & Graydon LLP
    Blake, Cassels & Graydon LLP
  • Article

    Canadian Tax Laws: A Review Of 2018 And A Look Ahead To 2019

    Each year at this time we offer a look back at some of the more significant income tax developments in Canada affecting domestic and international business over the past year and a look ahead ...
    CanadaTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    Federal Budget 2025

    On November 4, 2025 (Budget Day), Canada's Minister of Finance and National Revenue, François-Philippe Champagne, tabled the Liberal Government's budget...
    CanadaTax
    McCarthy Tétrault
    McCarthy Tétrault
  • Article

    Highlights Of Canada's 2019 Federal Budget

    Last week, Bill Morneau tabled the Liberal government's fourth budget, the last before the federal election slated for the fall.
    CanadaTax
    Torys
    Torys
  • Article

    Do’s And Don’ts Of IT Licensing — Top 10 Tips

    What are the risks, issues and contractual terms to be aware of for technology license agreements? To create effective licenses for both licensors and licensees, it is important to have an understanding of the common legal and business issues that arise in negotiating licenses by following these "Top 10" tips. Software, Web sites, e-commerce transactions and information technology generally can involve many different forms of intellectual property (IP).
    CanadaStrategy
    Blake, Cassels & Graydon LLP
    Blake, Cassels & Graydon LLP
  • Article

    Canadian Tax @ Gowlings - December 21, 2011 - Volume 8, Number 5

    Tax is constantly evolving, and sometimes obsolete provisions need to be pruned.
    CanadaTax
    Gowling WLG
    Gowling WLG
  • Showing 301–320 of 393 results

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