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The United States Senate approved the September 21, 2007 protocol (the Protocol) to the Canada-United States Income Tax Convention (the Treaty) on September 23, 2008.

The U.S. Tax Court issued an opinion on February 17, 2010 clarifying the source of guaranty fees for U.S. tax purposes, which has previously been subject to confusion.

The American Jobs Creation Act of 2004 (AJCA) contains numerous international tax provisions that may be relevant to companies with foreign subsidiaries. Section 422 enables a U.S. corporation to repatriate eligible earnings from offshore affiliates during a designated taxable year with a modest U.S. tax cost. If specified investment requirements and other criteria are met, the taxpayer may claim an 85% dividends received deduction, but no foreign tax credit or deduction for foreign taxes paid.

The tool is the latest addition to the Canadian version of Blue J Tax and is available for immediate use by subscribers to the platform across the country.

On September 21, 2016, Canada and Israel entered into a new income tax convention intended to replace the existing Canada-Israel Income Tax Convention.

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 October 24, 2012, the Minister of Finance (Canada) tabled a Notice of Ways & Means Motion (the "Notice of Ways & Means Motion") containing almost 1000 pages of technical amendments to the Income Tax Act (Canada) (the "ITA").

Budget 2010 proposes significant changes to Canada’s international tax rules. Effective for dispositions after March 4, 2010, the liability for Canadian tax on gains from the disposition of Canadian investments will be eliminated in many cases, together with the reporting and withholding requirements, enhancing the ability of Canadian businesses to attract foreign venture capital.

On May 20, 2015, the U.S. Treasury Department released proposed changes to the U.S. model tax treaty, which has not been updated since 2006.

On May 19, 2015, the Court of Quebec released its judgment in Emballages Starflex Inc. v. Agence du Revenu du Québec...

In a report just released by the U.S. Treasury, 3,415 Americans renounced their citizenship last year. This number is up from 2,999 in 2013, which was itself a record.

On December 10, 2008, the Advisory Panel on Canada’s System of International Taxation delivered its lengthy final report and recommendations for change to the Canadian Minister of Finance.

Canada is expected to notify the OECD within the next few months that it has ratified the MLI.

Canada, along with 67 other jurisdictions, were the original signatories to the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the "MLI").

On September 16, 2015, the Honorable Mr. Justice Martineau rendered summary judgment in the matter of Hillis and Deegan v. The Attorney General of Canada, docket T-1736-13 (2015 FC 1082).

Canada has a series of bilateral tax treaties. These have evolved over time to include various anti-avoidance, and anti-treaty shopping rules.

On May 16, 2008, the Tax Court of Canada released two important decisions dealing with the concept of permanent establishment ("PE") under treaty law: American Income Life Insurance Co. v. R., 2008 D.T.C. 3631 and Knights of Columbus v. R., 2008 D.T.C. 3648.