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  • Article

    Alta Energy: FCA Confirms That Treaty Shopping Is Not Abusive (For Now …)

    On February 12, 2020, in Canada v Alta Energy Luxembourg S.A.R.L. (2020 FCA 43), the Federal Court of Appeal ("FCA") unanimously held that the general anti-avoidance rule ...
    CanadaTax
    Fasken
    Fasken
  • Article

    Beware CRA's Ability To Share Information With Foreign Tax Authorities Using Tax Information-Exchange Provision In Bilateral Tax Treaties And Tax Information Exchange Agreements: A Canadian Tax Lawyer's Primer

    The trend of digitizing tax-related information provides taxing authorities around the world an invaluable opportunity to exchange information.
    CanadaTax
Rotfleisch & Samulovitch P.C.
Rotfleisch & Samulovitch P.C.
  • Article

    Taxation Measures In The 2010 Federal Budget

    Finance Minister Jim Flaherty delivered the Federal Budget on March 4, 2010. The Budget leaves untouched previously-enacted reductions in corporate income tax rates through 2012.
    CanadaTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    Sept secteurs sous la loupe de L'agence du revenu du Canada

    Le budget fédéral pour l'année 2021 a alloué un montant additionnel de 304.1 millions de dollars à l'ARC afin de l'aider dans sa lutte contre l'évasion fiscale et l'évitement fiscal agressif.
    CanadaTax
    Fasken (French)
    Fasken (French)
  • Article

    Selected US Tax Developments

    Canadians who emigrate to the United States or elsewhere face many decisions and considerations associated with departure, but careful tax planning should not be an afterthought.
    GlobalTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    The Long History Of Taxation

    As we commence the new year (2020), we prepare ourselves for what awaits us: spring showers, flowers, and the hand of the tax collector reaching into our pockets.
    CanadaTax
    KPK Law LLP
    KPK Law LLP
  • Article

    Emigrating From Canada To Barbados: Can You Recover Canadian Departure Tax By Disposing Of Property As A Barbados Tax Resident?

    Opportunities for tax planning are virtually limitless. Provided your strategy aligns with both the wording and purpose of applicable Canadian tax legislation (in order to avoid a GAAR attack), it will likely withstand any challenges.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    IRS Should Allow QCIV Self-Designation Under FIRPTA

    As part of the PATH Act, Congress enacted a new exemption from FIRPTA for foreign entities that are "qualified shareholders" of certain publicly traded real estate investment trusts and other entities.
    CanadaTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    Corporate Tax Mergers & Acquisitions: Recent Developments

    This article focuses on cross-border issues that arise in connection with M&A transactions affecting U.S. shareholders of Canadian companies, Canadian shareholders of U.S. companies and transactions affecting both U.S. and Canadian companies in acquisitions of one by the other.
    CanadaStrategy
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    Globalization Of Wealth: Canadian Tax Considerations For Executors Of Cross-Border Estates

    As families, investments and business interests increasingly span multiple countries, it is not uncommon for Canadian residents to have dual citizenship and property in several jurisdictions. Where a Canadian resident individual who holds dual Canadian-U.S. citizenship owns assets in several countries, multiple wills are often recommended, with a separate will for each jurisdiction administered by a local executor.
    CanadaTax
    Fasken
    Fasken
  • Article

    Highlights Of Canada’s 2010 Federal Budget

    The federal budget tabled on March 4, 2010 contains a number of unexpected proposed amendments to Canada’s Income Tax Act
    CanadaTax
    Torys
    Torys
  • Article

    Hips Don’t Lie—And Neither Do Flight Records: A Canadian Tax Lawyer On What The Shakira Case Teaches High-Net-Worth, Mobile Canadians

    Colombian global superstar Shakira has won a major legal battle in the Shakira tax case. Spain’s High Court acquitted her of tax fraud allegations concerning the 2011 tax year and ordered the Spanish government to return more than US$64 million in previously collected fines and interest.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Think Canada For Global Projects And Global Expansion: Canadian Corporate And Tax Considerations For Foreign Expansion To And From Canada

    From its earliest days, Canada has been a nation focused on international trade – a characteristic that continues today. In 2021, Canadian exports of goods and services...
    CanadaTax
    Aird & Berlis LLP
    Aird & Berlis LLP
  • Article

    50 Ways to Leave – Tax Considerations For Departing Canadian Individuals

    Residency is central to the taxation of Canadians.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Are You Entitled To Receive The Canada Child Benefit (CCB)? 'Tax Residence' Is Key, Plus How To Determine If You're Tax Resident

    Where it applies, subsection 122.61(1) of the Income Tax Act entitles an "eligible individual" to the Canada Child Benefit ("CCB"). The CCB is defined as an overpayment to ensure it remains a tax-free payment to the recipient.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Canadian Government Issues Guidance On International Income Tax Issues Raised By The COVID-19 Crisis

    On May 22nd, 2020, the Canada Revenue Agency ("CRA") released guidance (the "Guidance") on how it will deal with certain international tax issues that have arisen as a result of the travel restrictions ("Travel Restrictions"), or ...
    CanadaTax
    McCarthy Tétrault
    McCarthy Tétrault
  • Article

    Tax Issues For Americans Moving To Canada: A Cross-Border Planning Guide

    US citizens moving to Canada face unique tax challenges as they remain subject to IRS obligations while becoming Canadian tax residents. From TFSA reporting traps and PFIC complications to estate planning with non-citizen spouses, understanding the cross-border implications before relocating can prevent costly compliance failures and optimize your dual-country tax position.
    CanadaTax
    Altro LLP
    Altro LLP
  • Article

    Tax Withholding Obligations Of Non-Resident Employers: Further Exemption Details Released

    In its 2015 Budget, the Canadian federal government announced its intention to exempt "certified" non-resident employers from the obligation to withhold and remit income tax in respect of certain employees that perform duties in Canada.
    CanadaTax
    McMillan LLP
    McMillan LLP
  • Article

    Velcro Canada Inc. v. The Queen: Riding Prévost Car To Victory

    In the tax world, "treaty-shopping" occurs when a person resident in Country A organizes a legal entity in, and directs income through, Country B, solely to secure benefits under a tax treaty between Countries B and C that would not be available to a resident of Country A, typically preferential tax treatment for income sourced from Country C.
    CanadaTax
    McCarthy Tétrault
    McCarthy Tétrault
  • Article

    Canada Border Services Agency Update: Expecting A Customs Audit?", Focus On Tax, June 2011

    The Canada Border Services Agency (CBSA) has recently released its 23 "target" national audit priorities for the coming year.
    CanadaTax
    Dentons Canada LLP
    Dentons Canada LLP
  • Showing 381–400 of 543 results

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