Under the Foreign Account Tax Compliance Act, foreign financial institutions may avoid withholding tax that will otherwise be imposed on U.S.-source payments made on after July 1, 2014, by registering with the IRS and agreeing to report to the IRS certain information about their U.S. accounts, including accounts of certain foreign entities with substantial U.S. owners.

In an attempt to arrive at an agreement before the Christmas break, negotiators from the U.S. House of Representatives and the U.S. Senate released on December 15, 2015 statutory language...

Mr. Russell Porisky the founder of Paradigm, a business which counseled people across Canada to commit fraud by evading tax was sentenced to five and a half years in jail, and a fine of $259,482.

The 2015–2016 edition of our planning guide is an up-to-date reference on the latest business and individual tax developments.

In our firm's latest podcast, Kenneth Keung and Kim G C Moody discuss tax issues that need to be considered when non-residents of Canada...

The Internal Revenue Service and the U.S. Treasury Department recently released amendments to the final FATCA regulations, in part so as to provide better coordination with the intergovernmental agreements.

In this article, originally published in Tax Management International Journal, Davies lawyers Zachary Kling, Jonathan Rhein, Jennifer Lee and Peter Glicklich explain what...

On August 29, 2019, Canada completed its domestic ratification of the OECD-sponsored Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting

Alberta couple have been fined almost half a million dollars after they pled guilty in December 2015 to evading $486,000 in federal income tax in 2007 and 2008.

As noted in our previous post, the recently signed Inter-Governmental Agreement between the Canada and the U.S. relating to FATCA will modify the FATCA reporting obligations for Canadian financial institutions.

On May 29, 2019, Darcy Moch, Greg Johnson and Jared Mackey of Bennett Jones participated on a witness panel before the Standing Senate Committee

Subparagraph 212(1)(d)(vi) of the Income Tax Act (Canada) exempts non-residents of Canada from non-resident withholding tax on Canadian royalty payments received in respect of a copyright for the production or reproduction of any literary, dramatic, musical or artistic work.

CRA has begun to collect the fingerprints of Canadians who are accused of tax evasion, even though they may never be convicted.

The long awaited instructions for Form W-8BEN-E were finally posted on the IRS website on June 24, 2014.

There may be IRS withholding obligations under the Foreign Investment in Real Property Tax Act when a non-U.S. person disposes of a U.S. real property interest.

On June 22, 2023, Bill C-47 - An Act to implement certain provisions of the budget tabled in Parliament on March 28, 2023 received royal assent, implementing the new mandatory disclosure rules.

On November 11, 2012, the Government of Canada signed a tax treaty with the Government of the Hong Kong Special Administrative Region of the People's Republic of China.

On August 14, 2012, the Department of Finance released for consultation draft legislative proposals that implement measures included in the March 29, 2012 federal budget. Comments on the proposals are due by September 13, 2012.

This global automatic information exchange initiative is based on each jurisdiction’s participation in the OECD’s Multi-lateral Convention on Mutual Administrative Assistance in Tax Matters.

Tax evasion has followed business models and is marketed and even franchised to the Canadian public at large, but founders of 2 different tax evasion systems have recently been jailed.