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The Canadian federal government has been concerned for some time about "treaty shopping" by non-residents.

In light of the Coronavirus (COVID-19) pandemic the government of Saskatchewan is offering relief to businesses that are directly impacted by COVID-19.

On January 15, 2016, Canada and Taiwan entered into an "Arrangement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income" (the "Arrangement").

In Garron and Garron, Trustees of the Garron Family Trust v. The Queen, released by the Tax Court of Canada on September 10, 2009, Madam Justice Woods applied a new and novel test to determine the residency of a trust.

The CRA has general powers to require persons to provide information related to a tax audit however these general powers are limited, such that, the CRA cannot require persons to provide third party documents without judicial authorization.

On December 15, 2008, the Fifth Protocol to the Canada - US Income Tax Convention (Treaty) came into force.

Cross-border couples face complex tax implications when a Canadian spouse names their U.S. citizen partner as beneficiary of a Tax-Free Savings Account (TFSA). While TFSAs offer tax advantages in Canada, the IRS treats income from these accounts differently for U.S. persons, creating unexpected reporting obligations and potential tax consequences that require careful estate planning coordination between both countries.

Canada has one of the most highly educated and skilled workforces in the world. This combined with free healthcare and accessible childcare rates makes Canada one of the most attractive regulatory regimes to set up shop.

Canada is a signatory to the Multilateral Convention to Implement Tax Related Measures to Prevent Base Erosion and Profit Shifting (the "MLI")...

To become certified, the qualifying non-resident employer must file Form RC473, Application for Non-Resident Employer Certification.

In February we wrote about a discussion draft of Action 6 of the Action Plan on Base Erosion developed by the Organisation for Economic Co-Operation and Development at the request of the G20.

The Canada Revenue Agency (CRA) has amended its administrative position on Canadian withholding tax obligations on payments of interest, dividends, royalties, etc., to non-residents to be effective on January 1, 2012 (now extended to January 1, 2013).

Part III of this Toronto tax lawyer tax rectification article discusses the Supreme Court of Canada's decision and its tax planning implications.

section 116 clearance certificate must be obtained by a non-resident vendor where there is a disposition of taxable Canadian property (TCP).

Every acquisition requires careful tax planning early on in the process, especially when dealing with cross border acquisitions.

Initially announced in the 2015 federal budget, the Department of Finance released draft legislative proposals on July 31, 2015 that provide certain non-resident employers an exemption from Canadian payroll withholdings...

The Income Tax Act (Canada) contains an extensive set of transfer pricing rules designed to ensure that cross-border transactions entered into between Canadian taxpayers and non-residents with which they do not deal at arm’s length are priced on an arm’s length basis.