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Article
Top Court Blesses Treaty-Shopping Arrangement: The Alta Energy Decision
The Supreme Court of Canada (SCC) recently rendered its eagerly awaited decision in Canada v Alta Energy Luxembourg S.A.R.L., 2021 SCC 49.
CanadaTax
Davies Ward Phillips & Vineberg LLP
Article
Two Recent Tax Shelter Decisions Require Supreme Court Clarification
In 1995, the Department of Finance substantially amended the tax shelter rules under the Income Tax Act (Canada) (the Act). Until recently, they had not been considered by the Federal Court of Appeal.
CanadaTax
Blake, Cassels & Graydon LLP

Canada-US Estate Planning: A Complete Guide For Snowbirds And Cross-Border Families

Canadians who own US property, hold American investments, or have family members with US citizenship face a complex web of estate tax obligations spanning two countries. Without proper coordination, your heirs could face double taxation, frozen assets during lengthy Florida probate proceedings, or unexpected tax bills that consume a significant portion of their inheritance.

CanadaFamily and Matrimonial

Canadian Partnership Status For Income Tax: Toronto Tax Lawyer Guide

The Canadian legal environment provides businesses with a number of different choices for legal forms to structure themselves, most prominently corporations, sole proprietorships, partnerships and limited partnerships.

Rotfleisch & Samulovitch P.C.

Impact Of The New Tax Protocol On Limited Liability Companies, Unlimited Liability Companies And Debt Financing:

The Fifth Protocol to the Canada - U.S. Tax Convention, dated September 21, 2007 (the "Protocol") will have a significant impact on cross-border transactions given the proposed treatment for hybrids and the elimination of withholding tax on interest on arm's length cross-border debt.

MLI Big Picture Changes Update 2.0

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting ("MLI") is a multilateral treaty

McCarthy Tétrault

New Era, New Disclosure Obligations

In a case argued by Davies, the Court of Québec rendered a judgment on December 10 setting out, for the first time, the conditions that must be met for the electronic disclosure of evidence by the Crown to be "reasonably accessible", ...

Davies Ward Phillips & Vineberg LLP

OECD Proposes Significant International Tax Changes That Will Impact Multinationals

Earlier in 2019, the OECD published its Programme of Work [PDF] to Develop a Consensus Solution to the Tax Challenges Arising from the Digitalization of the Economy (Program of Work)

Osler, Hoskin & Harcourt LLP

The Revenue Rule In Tax Law

A country's revenue laws reflect its political sovereignty and create property rights that affect relationships. Hence, sovereign states will not enforce the revenue laws of foreign...

Update On Canada's Implementation Of The OECD's Plans To Combat Tax Avoidance

On October 5, 2015, the OECD released fifteen Final Reports on its project entitled, Base Erosion and Profit Shifting ("BEPS")...

Gardiner Roberts LLP

Tax Law Bulletin - New Protocol To The Canada-US Tax Treaty: Withholding Tax On Cross-Border Payments

Canada and the United States signed the widely anticipated Fifth Protocol (the “Protocol”) to the Canada-US Income Tax Convention (the “Treaty”) on September 21, 2007.

CEWS Update: Review Of New Rules And CRA Guidance

Earlier this year, Parliament enacted legislation adopting the Canada Emergency Wage Subsidy (CEWS) through amendments to the Income Tax Act (Canada) (Act).

CanadaEmployment and HR

Davies Ward Phillips & Vineberg LLP

Alta Energy: Supreme Court Of Canada Finds That The General Anti-Avoidance Rule Does Not Preclude Treaty Shopping To Avoid Capital Gains Tax

Canada v. Alta Energy Luxembourg S.A.R.L., 2021 SCC 49: In a decision with important implications for multinational corporations doing business in Canada, the Supreme Court of Canada ("SCC") ...

McCarthy Tétrault

Canadian Departure Tax: Canadian Tax Lawyer Guidance

When taxpayers emigrate from Canada, for tax purposes they are deemed to have disposed of their capital assets even though no assets are actually sold.

Rotfleisch & Samulovitch P.C.

Canadians Could Gain Greater Access To Foreign Capital

Canadian borrowers are on the verge of gaining unprecedented access to foreign capital. Canada has agreed that it will soon no longer impose withholding tax on interest paid to U.S. residents. Canada has also announced that it will extend this treatment to interest paid to arm’s-length non-residents of any country.

How Does Canada Tax Non-Resident Pro Athletes? – A Canadian Tax Lawyer's Analysis

During a post-fight interview in June 2020, Ultimate Fighting Championship (UFC) welterweight contender "Platinum" Mike Perry voiced his frustration about grappling with international tax rules.

Rotfleisch & Samulovitch P.C.

Income Tax Update From The Supreme Court Of Canada: The GAAR Does Not Apply To Treaty Shopping

On November 26, 2021, the Supreme Court of Canada released its decision and reasons in Her Majesty the Queen and Alta Energy Luxembourg S.A.R.L., 2021 SCC 49.

Bennett Jones LLP

Canadian Tax @ Gowlings - September 2005

This article provides a brief overview of recent developments in Canadian Tax Law.

Conrad Black: Resident Here, Resident There, Resident Everywhere?

It is common for an individual to be resident in more than one country at a given time (i.e., to be a "dual resident").

CRA Releases Guidance On Residency, Permanent Establishment And Other International Issues Arising During The COVID-19 Pandemic

The global travel restrictions caused by the COVID-19 pandemic have resulted in some individuals involuntarily remaining in one jurisdiction or being unable to enter another jurisdiction.

Osler, Hoskin & Harcourt LLP

Showing 341–360 of 543 results

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