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The decision of the Supreme Court of Canada last month in Century Services Inc. v. Canada is of striking interest to the tax and insolvency bars

Canada has one of the largest tax treaty networks in the world. Its Canadian tax treaties are designed to prevent double taxation, allocate taxing rights between countries, and reduce Canadian non-resident withholding tax on cross-border dividends, interest, royalties, and similar payments.

Canadian taxpayers facing cross-border tax disputes have access to several treaty-based relief mechanisms, including the Mutual Agreement Procedure (MAP), Accelerated Competent Authority Procedure (ACAP), and Advance Pricing Arrangements (APA). When competent authorities cannot reach agreement, mandatory binding arbitration may be available under certain tax treaties to resolve double taxation issues and ensure consistent treatment across jurisdictions.

Many immigrants had a career before they moved to Canada and they might be eligible to receive a foreign pension from another country.

Under subsection 128.1(4) of the Canadian Income Tax Act, a Canadian emigrating to another jurisdiction is subject to a "deemed disposition" on qualifying property.

When a taxpayer ceases to be a Canadian tax resident, paragraph 128.1(4)(b) of Canada's Income Tax Act deems the taxpayer to have disposed of almost all property (including cryptocurrency, non-fungible tokens, and other digital assets) at fair market value.

When a taxpayer ceases to be a Canadian tax resident, paragraph 128.1(4)(b) of Canada's Income Tax Act deems the taxpayer to have disposed of almost all property (including cryptocurrency, non-fungible tokens (NFTs), and other digital assets) at fair market value.

The first Liberal budget in 10 years ("Budget 2016") is designed to "restore hope" and "reward hard work."

The Advisory Panel on Canada's System of International Taxation released its Final Report: Enhancing Canada's International Tax Advantage on December 10, 2008.

In this article, the authors examine the extent to which Canada's new treaties with Taiwan and Israel reflect its involvement and concern.

The case of Univar, in which the Tax Court of Canada upheld a $30 million tax assessment on an alleged $600 million surplus strip, raises domestic and international surplus stripping issues...

On April 7, 2022 ("Budget Day"), Finance Minister Chrystia Freeland delivered Canada's budget for 2022.

On May 11, 2009, the U.S. Treasury Department released details of a major reform to the U.S. international tax rules proposed by President Obama in connection with the Administration’s fiscal 2010 budget.

Cross-border tax structures periodically optimize available tax treaty benefits having regard to the differences between various bilateral tax treaties.

L'année écoulée a été marquée par un nombre de développements jurisprudentiels importants qui continuent à façonner l'interprétation et l'administration du régime d'imposition du Canada.

When Alice found herself in Wonderland, she observed a recognizable world that had been turned on its side.

Minister of Finance Flaherty takes pride in the integrity measures he has introduced since 2006. Last year, Budget 2013 touted over 75 measures aimed at improving integrity and closing tax loopholes