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Certain federal and provincial tax considerations are relevant when one is conducting business in Canada. While Canadian residents are subject to tax on worldwide...

The federal budget (Budget 2016) tabled on March 22 contains a number of proposed amendments to Canada's Income Tax Act.

A corporation’s residence for tax purposes and the jurisdiction under which it is incorporated are legally distinct concepts. The corporate statute that governs a corporation, whether the Canada Business Corporations Act (“CBCA”) or a provincial equivalent, dictates its internal governance rules, but it does not, on its own, determine where the corporation is resident in Canada for the purposes of the Income Tax Act.

Tax implications for Canadian trusts

In Canada, an income tax is levied by both the federal and provincial/territorial governments, and a variety of other taxes, including fed­eral and provincial value-added and sales taxes, are also imposed.

The Tax Court of Canada's decision in ExxonMobil Canada Resources Company v R addresses the deductibility of $36 million in feasibility study costs for the Alaskan Gas Pipeline Project, examining whether transfer pricing rules apply to adjust or deny the deduction. The case explores critical questions about source of business income, arm's length transactions between related parties, and the application of Part XIII non-resident withholding tax in the context of cross-border pipeline development ventures.

From a tax perspective, the headline news is that Budget 2018 completes the Government of Canada's general retreat from the astounding July Proposals to address passive investment income in private corporations.

This article provides a brief overview of Canada's advance pricing arrangement ("APA") program. Canada's APA program has existed for over two decades.

Malgré le déficit qui ne cesse d'augmenter, le budget 2017 ne contient aucune augmentation de taxe générale ou autres mesures qui pourraient changer la donne, lesquelles mesures...

Following the resumption of Parliament, the minority Harper government released its fifth Budget on March 4, 2010 (Budget 2010). The focus of Budget 2010 is to continue to support economic growth, jobs, infrastructure and industry.

With the Canada Revenue Agency (CRA) deploying massive resources to crack down on perceived tax avoidance, it's now more important than ever to stay up to date with new CRA policies...

The U.S. State Department estimates that approximately 7.2 million U.S. citizens live abroad, plus an indeterminate number of green card holders.

On October 5, 2015, the OECD released its final reports relating to the OECD/G20 base erosion and profit shifting (BEPS) initiative.

In the midst of a deteriorating economic climate, on the heels of another inconclusive federal election, and following an extraordinary Parliamentary crisis that included the replacement of the Opposition Liberal Party leader, the political context and consequences of the 2009 Budget are as much the focus as its conten

La planification fiscale transfrontalière repose généralement sur l'hypothèse selon laquelle, si les conventions juridiques sont structurées correctement et que le libellé d'une convention fiscale est respecté, un taux réduit de retenue à la source s'appliquera, le cas échéant. Le litige opposant Husky Energy Inc. (« Husky ») à l'Agence du revenu du Canada montre que cette hypothèse n'est peut-être plus valable.

On March 22, 2017 (Budget Day), Finance Minister Bill Morneau tabled in the House of Commons the Liberal Government's second budget, Building a Strong Middle Class (Budget 2017).

The Minister of Finance (Canada), the Honourable Chrystia Freeland, presented the Government of Canada's (the "Federal Government") 2021 Federal Budget ("Budget 2021") on April 19, 2021