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Searching Content from Canada indexed under Tax Treaties ordered by Published Date Descending.
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1
The Year In Review: An Annual Publication Of The ABA/Section Of International Law - International Tax
2019 by the American Bar Association. Reprinted with permission. All rights reserved. This information or any or portion thereof may not be copied or disseminated in any form ...
Canada
8 Oct 2019
2
Tax Treatment Of US-Owned Canadian ULC – A Toronto Tax Lawyer Analysis
To many people, an unlimited liability company (ULC) may sound like a contradiction in terms.
Canada
25 Sep 2019
3
Tax Treaty Benefits Threatened As Canada Completes Ratification Of OECD's Multilateral Instrument
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
Canada
9 Sep 2019
4
Canada Ratifies The Multilateral Instrument
On June 7, 2017, Canada along with numerous other jurisdictions signed the Organisation for Economic Co-operation and Development's
Canada
6 Sep 2019
5
Income Tax For Canadians Working At Sea – A Canadian Tax Lawyer's Perspective
If you are a Canadian citizen or resident working or planning to work at sea, then it may seem counterintuitive to learn that the income you earn from that job will be subject to Canadian income tax as though it was earned here in Canada.
Canada
26 Aug 2019
6
A Canadian Tax Lawyer's Perspective On Emigration Tax Issues
Emigrating from Canada has a multitude of tax implications including which country can tax particular income and the Canadian tax owed for emigrating.
Canada
20 Aug 2019
7
OECD Work Program To Address The Digitalized Economy
On May 31, 2019, as one of the main areas of focus of the ongoing work on the Base Erosion and Profit Shifting ("BEPS") project, Members of the OECD/G20 Inclusive Framework on BEPS ("Framework")
Canada
16 Aug 2019
8
Private Client Law In Canada: Overview
A Q&A guide to private client law in Canada. The Q&A gives a high level overview of tax; tax residence; inheritance tax; buying property; wills and estate management; succession regimes; intestacy; trusts; co-ownership; ...
Canada
15 Aug 2019
9
OECD Public Consultation Document And Public Commentary On The Tax Challenges Of Digitalisation
In February and March of 2019, the OECD organized a public consultation process, releasing a consultation document on February 13, 2019, inviting public comments up until March 6, 2019, and holding a conference where industry...
Worldwide
13 Aug 2019
10
Canada Enacts The OECD-Sponsored Multilateral Instrument
Canada is expected to notify the OECD within the next few months that it has ratified the MLI.
Canada
7 Aug 2019
11
Transfer Pricing: What's New In Canada (Part I)
Since 2012, there have been unprecedented developments in Canada and globally in the area of international tax. The sheer volume and complexity
Canada
5 Aug 2019
12
Tax Filing Obligations For Non-Resident Canadian Partnerships
section 116 clearance certificate must be obtained by a non-resident vendor where there is a disposition of taxable Canadian property (TCP).
Canada
1 Aug 2019
13
Vesting Off Interests In Land: The Latest Dianor Decision
The Ontario Court of Appeal has released its much anticipated second decision in Third Eye Capital Corporation v. Ressources Dianor Inc./Dianor Resources Inc.
Canada
29 Jul 2019
14
Update On The Status Of The Multilateral Instrument In Canada
On June 21, 2019, one year after it was tabled in the House of Commons, Bill C-82, An Act to implement a multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting...
Canada
12 Jul 2019
15
Modifications Au Paysage Canadien Des Accords Fiscaux Internationaux : Entrée En Vigueur De l'Instrument Multilatéral Au Canada
Le 21 juin 2019, le projet de loi C‑82, Loi mettant en œuvre une convention multilatérale pour la mise en œuvre des mesures relatives aux conventions fiscales pour prévenir l'érosion de la base
Canada
10 Jul 2019
16
Impact Of Recent International Tax Developments On Canada
Recent international tax changes proposed by the OECD could significantly impact the cross-border activities of Canadians – particularly with respect to tax planning strategies that shift profits to low or no-tax jurisdictions.
Canada
5 Jul 2019
17
Canada Close To Ratifying The Multilateral Instrument
Bill C-82, An Act to implement a multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting, has received royal assent.
Canada
5 Jul 2019
18
Case Comment – MNR v Roofmart Ontario Inc. ("Roofmart")
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.
Canada
4 Jul 2019
19
Canadian Snowbirds Should Know These US Tax Residence Rules – Tips from A Canadian Tax Lawyer
If none of the factors are conclusive which is a very rare situation, you must ask the competent authority of each country to make a decision.
Canada
18 Jun 2019
20
Will He Stay Or Will He Go? The Kawhi Leonard Saga
Four bounces off the rim… and in! A thundering slam dunk over the presumptive NBA MVP. Nailing two free throws in the final 0.9 seconds—sealing the first ever NBA Championship for the Toronto Raptors.
Canada
17 Jun 2019
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