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Cross‑border tax planning typically assumes that if you structure legal agreements correctly and satisfy a tax treaty’s wording, a reduced withholding rate will follow where applicable. Husky Energy Inc.’s (“Husky”) fight with the Canada Revenue Agency suggests that assumption may no longer be safe.

Canadians with US property, rental income, or extended winter stays face specific IRS reporting requirements that go far beyond simple tax residency rules. Understanding which forms to file, when to file them, and how FIRPTA withholding, the Substantial Presence Test, and cross-border tax credits interact can mean the difference between routine compliance and costly penalties.

Each year at this time, we offer a look back at some of the more significant business and international tax developments in Canada and the United States over the past year.

With numerous spending initiatives released in the days leading up to the January 27, 2009 federal budget, many wondered whether the tabling of the Budget itself would be anti-climactic.

This Perspective takes a short look back at tax developments in the U.S. and Canada in 2009 and offers a longer look forward to 2010 for possible developments affecting the U.S. and Canadian taxation of international companies and investors.

A non-resident of Canada is generally taxable under the Income Tax Act (Canada) (Act) on any income or gains arising on the disposition of taxable Canadian property (TCP), except where the non-resident is entitled to a treaty exemption.

It has been over a month since the March 4, 2010 release of the Canadian Federal Budget (the "Budget"). The Budget included proposed amendments that will significantly narrow the definition (the "TCP Definition") of "taxable Canadian property" ("TCP").

When facing a transfer pricing reassessment in Canada, taxpayers must navigate complex decisions about objecting through domestic appeals or pursuing treaty-based relief through the Mutual Agreement Procedure. This guide examines the strategic considerations, timelines, costs, and litigation factors that determine the optimal dispute resolution path, including the critical roles of fact and expert witnesses in refuting the CRA's assumptions.

On March 22, 2016, the Minister of Finance released the federal budget ("Budget 2016"). Below is a summary of the important tax changes contained in Budget 2016.

On March 29, 2012, Finance Minister Jim Flaherty delivered his 2012-2013 budget titled "Jobs Growth and Long-term Prosperity," in the House of Commons.

Under prevailing U.S. tax treaty policy, newly negotiated or renegotiated U.S. tax treaties must contain “limitation on benefits” (LOB) rules.

The current Canadian political, economic and social environment in 2018 is a mix of good and bad news.

While the lead-up to and the media coverage of the federal budget introduced on March 4, 2010 (the Budget) was heavily skewed towards deficit control, there was no shortage of significant tax proposals in the Budget, including the following:

Many Canadians dream of owning a vacation property in the United States, whether it is a condominium in Florida, a cottage in Vermont, or a ski chalet in Colorado, U.S. situs property represents both lifestyle and investment value.

The Canadian Government introduced its budget today ("Budget 2012") announcing a number of significant tax measures. The following is a brief summary of these measures, many of which come into effect today (the "Budget Day").

Foreign companies entering Canada face a complex tax landscape where home-country assumptions about deductibility, intercompany charges, and holding structures often don't apply.

John Tavares, NHL all-star and Captain of the Toronto Maple Leafs, is used to making headlines. Since signing with the Leafs in 2018, Tavares led the Leafs to their first second-round playoff appearance in nearly two decades, as well as the only recorded loss in the NHL to former Zamboni driver David Ayres in 2020.

La Convention multilatérale pour la mise en œuvre des mesures relatives aux conventions fiscales pour prévenir l'érosion de la base d'imposition et le transfert de bénéfices...