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For the last several years, the Organization for Economic Cooperation and Development ("OECD") and G20

The Fifth Protocol to the Canada-U.S. tax treaty (the Treaty) was ratified in December 2008, and for most purposes came into force in 2009. One of the more controversial measures contained in the Protocol is the new "anti-hybrid" rule in Article IV(7) of the Treaty.

On December 18, 2009, the Department of Finance (Finance) released a package of technical amendments to the foreign affiliate rules (the December 18th Proposals).

As a non-resident engaging in activities in Canada, it is important to understand whether your activities will result in income tax being levied.

Netherlands incorporated company held to be resident of Canada pursuant to its place of effective management in Canada.

On February 19, 2024, the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) released a report on Amount B (Amount B Report) that provides guidance on the simplified...

Under the Income Tax Act, Canadian residents must pay tax on their worldview income, while non-Canadian residents must pay tax on their Canadian-sourced income.

The clock is ticking for multinational enterprises and private equity firms with investments in the Canadian resource sector as anti-treaty shopping measures in the OECD's ...

In Canada v Alta Energy Luxembourg S.A.R.L., the Federal Court of Appeal (FCA) confirmed there was no abusive tax avoidance under Canada's general anti-avoidance rule (GAAR) ...

Taxpayers that have implemented cross-border tower financing structures and that have claimed a Canadian tax deduction for any U.S. taxes paid should revisit their structures carefully in light of the Tax Court of Canada’s recent decision in "FLSMIDTH Ltd., v. The Queen" (2012 TCC 3), which is the Court’s first decision concerning tower structures.

By now the 2015 holiday season is a distant memory, as are most of those well-meaning 2016 resolutions. For those individuals with both Canada and US tax issues, tax filing season is a few months away.

On June 26, 2012 the IRS announced new procedures that will enable non-resident US taxpayers who demonstrate "low compliance risk" to bring unfiled tax returns and related tax reporting obligations current and avoid potentially ruinous penalties.

The Treasury Department and Internal Revenue Service issued guidance for U.S. companies planning to repatriate earnings from controlled foreign corporations.

On March 4, 2010, the federal finance minister, the Honourable Jim Flaherty, released the 2010 federal Budget.

A partnership is not considered to be a separate legal entity for the purposes of Canadian income tax.

Canada's tax treaties are the third factor that may impact corporate tax residence.

Have you ever heard of the "Double Irish, Dutch Sandwich"? It is a complicated tax arrangement involving a parent corporation and three subsidiary corporations:

A registered charity in Canada is exempt from tax on taxable income if it meets the definition of a charity under section 149.1(1) of the Income Tax Act (the "Act").