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The estates of high net-worth individuals often cross borders. They might reside in one country, with assets in that country and elsewhere, and possibly family members residing are in other countries for work, education, or lifestyle reasons.

Article XXI(7) of the Treaty provides that where a Canadian donor makes a donation to a U.S. charity, the donor is entitled to claim a donation tax credit or deduction ...

On November 11, 2012, the Government of Canada signed a double tax treaty with the Government of the Hong Kong Special Administrative Region of the People's Republic of China.

The concept of paid-up capital is important for Canadian tax purposes in that, unlike certain of its treaty partners, Canada permits corporations to return capital to shareholders (even if they have accumulated earnings and profits for tax purposes), without payment of Canadian non-resident withholding tax.

Please see Sunita Doobay's latest article for the Canadian Tax Foundation's newsletter Canadian Tax Highlights which covers the U.S. Treasury Department and IRS Notice 2018-29, which makes three exceptions to the withholding requirement

COVID-19 Relief - Highly Affected Sectors Credit Availability Program (HASCAP) Guarantee

As the U.S. tax reform process continues, the comprehensive tax bill that passed the House of Representatives in May is now under active consideration in the Senate. Earlier this week, the Senate Finance Committee...

The Fifth Protocol (the Protocol) to the Canada-United States Income Tax Convention (the Treaty) modifies the Treaty with respect to contributions and benefits under pension plans (or certain other qualifying retire¬ment plans) by and on behalf of individuals residing in one Contracting State and working in the other (Commuters), as well as individuals who move from one Contracting State to the other on short-term (up to five years) work assignments, and continue to contribute to a plan in the f

NAFTA, the first multilateral free trade agreement between the United States, Mexico and Canada, became effective on January 1, 1994.

International tax avoidance has received considerable attention over the past few years.

The income tax treaty between Hong Kong and Canada (the "Treaty") first signed on November 11, 2012 has now been formally ratified and is in force as of October 29, 2013.

The IRS announced on May 21, 2018, the rollout of six additional compliance campaigns to be undertaken by the Large Business and International Division (LB&I).

This update is intended for those seeking additional insights into the 2018 Federal Budget including its impact on both domestic and multinational enterprises.

The FCA found that the object, spirit and purpose of the relevant Can-Lux Treaty provisions is reflected in the clear and simple text of the Treaty.

On May 19, 2020, the Canada Revenue Agency (the "CRA") released guidance respecting potential unexpected tax residency consequences resulting from the travel restrictions around COVID‑19.

Are you an investment dealer or a mutual dealer that has non-resident client accounts?

Last Thursday, the federal government released Budget 2012. It contained a number of proposals to improve efficiency and predictability in the review and approval process for major resource development projects while shifting tax incentives and strengthening environmental protection and free trade.

On December 15, 2008, the Fifth Protocol to the tax treaty between Canada and the United States entered into force.