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According to the Department of Finance, certain taxpayers were quick to identify deficiencies in paragraphs 95(2)(a.21) and (a.22).

The "Panama Papers" story hit the international press this week. An anonymous source leaked 11.5 million documents from Mossack Fonseca, the Panamanian firm believed to be the world's fourth largest provider of offshore legal services.

Although based in low-tax jurisdictions, Tax Court finds business reasons for investments overshadowed their tax benefits.

In the 2013 Budget, the Minister of Finance proposed making changes to the way Canadian taxpayers disclose their foreign investment holdings.

When a Canadian company creates a U.S.-based subsidiary, one of the first issues to be addressed is how to fund those operations.

An appeal was filed with the Federal Court of Canada in Vancouver seeking a declaration that the enforcementof the US FATCA on Canadian soil is unconstitutional.

With highly efficient labour markets, a solid institutional environment and a strong banking system, Canada has long been considered one of the most competitive nations in the world.

It seems that every day now there is an article of some sort addressing aggressive tax structures, often utilizing offshore entities, and the ramifications of (implied) inappropriate, underlying transfer pricing policies.

The April 2016 "Panama Papers" leak highlighted the attraction for transnational actors of the confidentiality available in certain offshore financial centres.

Since 2012, US citizens living in Canada (and elsewhere outside the US) have had two options to address income tax non-compliance issues.

On Monday April 4, 2016, the U.S. Treasury Department released a comprehensive set of temporary regulations that are designed to stop the flow of headline-grabbing U.S. corporate expatriation transactions commonly referred to as "inversion transactions."

I was called to testify regarding Canada’s legislation that implements the IGA between the US and Canada concerning the Foreign Account Tax Compliance Act.

The facts and a detailed analysis by our skilled Canadian tax lawyers follows on this watershed case.

The Foreign Account Tax Compliance Act was enacted by the United States Congress in order to deal with non-compliance by US taxpayers using foreign bank accounts.

Insolvency is a condition which is inherently chaotic. With the effluxion of time and no stabilization of distracting factors, value evaporates. Resources are not fully utilized – indeed in some instances, the scarce resources are completely discarded. Often these resources are intangibles – namely the goodwill which is built up in a business organization and its workforce. This is not the goodwill that enhances the value of a business by its location, say a newsstand in a subway station.

The Canada Revenue Agency (CRA) opened its Offshore Tax Informant Program (OTIP) on January 15, 2014.