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  • Article

    Implementation Of The Modified Nexus Approach (Action 5 Of BEPS) – Impact On IP Box Structures

    This insight aims at providing a general overview of the implementation of action 5 of BEPS (Base Erosion and Profit Shifting) in order to counter harmful practices that arise through national R&D...
    European UnionTax
    Gowling WLG
    Gowling WLG
  • Article

    OECD Public Consultation Document And Public Commentary On The Tax Challenges Of Digitalisation

    In February and March of 2019, the OECD organized a public consultation process, releasing a consultation document on February 13, 2019, inviting public comments up until March 6, 2019, and holding a conference where industry...
    GlobalTax
    Fasken
Fasken
  • Article

    Tax Residence Of Canadian Airline Pilots: No Simple Answer – A Canadian Tax Lawyer's Analysis

    Canada's jurisdiction to tax an individual's income turns on two connecting factors. The first is tax residence, which looks at the individual's social and economic ties with Canada.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Barbados International Business Corporations

    The Canadian manufacturing industry is facing significant business and structural challenges that have seen their level of importance relative to other sectors in the economy, such as services, fall.
    CanadaTax
    Gowling WLG
    Gowling WLG
  • Article

    Latest Step In CRA's New Audit Approach: "Risk Assessment" Interviews With Large Businesses

    In the next few weeks, the Canada Revenue Agency ("CRA") plans to conduct individual risk-assessment interviews with a select group of 50 large businesses.
    CanadaTax
    Borden Ladner Gervais LLP
    Borden Ladner Gervais LLP
  • Article

    Part-Year Residence

    Your status as a tax resident determines the extent to which Canada may tax your income. Canada taxes its residents on their worldwide income.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    CRA Issues Guidance On Tax Issues Raised By Covid-19 Crisis & Travel Restrictions

    As a consequence of COVID-19, governments and businesses around the world have introduced travel restrictions to protect their citizens and employees.
    CanadaCoronavirus (COVID-19)
    Gowling WLG
    Gowling WLG
  • Article

    Post Crisis Bank Losses Prompt Call For Better Tax Governance

    According to the OECD, the world's banks suffered write-downs and losses of US$1.3 trillion up to January 2010 due to the 2008 financial crisis.
    CanadaTax
    KPMG
    KPMG
  • Article

    Canada-Israel Income Tax Convention & The Making Of Aliyah From Canada To Israel – Canadian Tax Lawyer Analysis

    Aliyah is the emigration of the Jewish people and their descendants from diaspora to Israel, for the purpose of making Israel their homeland.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    U.S. Court Rejects Formula Apportionment in Computing Business Profits of a Foreign Bank Branch

    In December 2005, the U.S. Court of Federal Claims held that National Westminster Bank, PLC, a U.K.-based multinational bank (NatWest), was not required to apply the formula-based apportionment of interest expense required under domestic U.S. tax law and ruled instead that it was entitled to rely on the properly maintained books and records of its U.S. branch in computing its business profits. In its third decision in the continuing tax dispute, the court provided some valuable guidance on the p
    CanadaTax
    Osler, Hoskin & Harcourt LLP
    Osler, Hoskin & Harcourt LLP
  • Article

    Canada-Barbados Tax Treaty - New Protocol

    On November 8, 2011, a new protocol (Protocol) amending the Canada-Barbados Income Tax Agreement (Treaty) was signed by the two countries, updating the Treaty to conform with current tax treaties and to reflect Canada’s commitment to promote exchange of tax information in accordance with OECD standards.
    CanadaTax
    McCarthy Tétrault
    McCarthy Tétrault
  • Article

    Canada Tax: 2008 In Review

    The Canadian economy was impacted in 2008 by the global economic crisis. Canadian stock markets and the Canadian dollar experienced severe volatility, influenced by swings in commodity prices (including particularly the price of oil).
    CanadaTax
    Borden Ladner Gervais LLP
    Borden Ladner Gervais LLP
  • Article

    Recent Court Decisions - May 2014

    The last year has provided no shortage of exciting and interesting tax cases that tax practitioners can learn from.
    CanadaTax
    Moodys Private Client Law
    Moodys Private Client Law
  • Article

    Supreme Court Of Canada Dismisses General Anti-Avoidance Rule In Tax Treaty Decision

    On November 26, 2021, the Supreme Court of Canada (the Court) released its decision in Canada v. Alta Energy Luxembourg S.A.R.L., 2021 SCC 49.
    GlobalTax
    Borden Ladner Gervais LLP
    Borden Ladner Gervais LLP
  • Article

    Bilan de l'année 2025 dans le domaine des différends fiscaux : Nouveau gouvernement et pouvoirs accrus de l'autorité taxatrice

    L'année 2025 aura été une année de transition pour les contribuables canadiens. Le nouveau gouvernement qui est entré en poste au fédéral s'est notamment écarté de nombreuses politiques fiscales...
    CanadaTax
    Blake, Cassels & Graydon LLP
    Blake, Cassels & Graydon LLP
  • Article

    Bumping Foreign Affiliate Shares Under The February 27, 2004 Proposals

    The February 27, 2004 foreign affiliate proposals present a number of interesting issues for an acquiror of a Canadian target company that owns foreign affiliate shares.
    CanadaTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    OECD Proposes Revisions To Tax Treaties To Prevent "Treaty Abuse"

    The OECD released a discussion draft for public consultation, BEPS Action 6: Preventing the Granting of Treaty Benefits in Inappropriate Circumstances.
    CanadaTax
    Osler, Hoskin & Harcourt LLP
    Osler, Hoskin & Harcourt LLP
  • Article

    Bare Trust Reporting In Canada: Where The Rules Stand, Which Arrangements Are Caught, And Who Must File For 2026

    After years of uncertainty and last-minute relief, Canada's bare trust reporting rules have finally been settled through Bill C-15. The new regime exempts most family arrangements while requiring commercial structures like nominee corporations and joint ventures to file detailed beneficial ownership disclosures starting with the 2026 taxation year. Understanding which arrangements are caught, which are exempt, and what steps to take now is essential for compliance before the March 31, 2027 filing deadline.
    CanadaTax
    Miller Thomson
    Miller Thomson
  • Article

    Canadian Budget 2016

    On March 22, 2016 the Minister of Finance released the federal budget. Below is a summary of the important tax changes contained in Budget 2016.
    CanadaTax
    Aird & Berlis LLP
    Aird & Berlis LLP
  • Article

    International Tax Issues At The Supreme Court Of Canada

    The Supreme Court of Canada (SCC) recently released two important decisions relating to international tax issues. The SCC provided meaningful guidance on the interpretation of one of Canada's bilateral tax treaties
    CanadaTax
    Blake, Cassels & Graydon LLP
    Blake, Cassels & Graydon LLP
  • Showing 421–440 of 543 results

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