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Searching Content indexed under Tax Treaties by McMillan LLP ordered by Published Date Descending.
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1
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
2
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
3
Canada And Israel Enter Into New Income Tax Convention
On September 21, 2016, Canada and Israel entered into a new income tax convention intended to replace the existing Canada-Israel Income Tax Convention.
Canada
6 Oct 2016
4
Tax Withholding Obligations Of Non-Resident Employers: Further Exemption Details Released
In its 2015 Budget, the Canadian federal government announced its intention to exempt "certified" non-resident employers from the obligation to withhold and remit income tax in respect of certain employees that perform duties in Canada.
Canada
28 Jan 2016
5
Taiwan – Canada Tax Arrangement Released
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").
Canada
27 Jan 2016
6
Canadian Branch Profits Tax – Challenging The Denial Of Treaty-Benefits For US LLCS
The Canada Revenue Agency continues to deny the benefits of the reduced "branch profits" tax rate.
Canada
4 Jul 2014
7
Budget 2014: Treaty Shopping
Following-up on certain policy statements contained in last year's federal budget, along with a consultation paper (the "Consultation Paper") released this past August ..
Canada
22 Feb 2014
8
Hong Kong - Canada Tax Treaty In Force
The income tax treaty between Hong Kong and Canada (the "Treaty") first signed on November 11, 2012 has now been formally ratified and is in force as of October 29, 2013.
Canada
2 Nov 2013
9
Federal Court Of Appeal Upholds Favourable Judgment On The Tax Treatment Of Cross-Border Investments
Non-residents frequently invest in Canada through foreign intermediaries. A key consideration in structuring such investments is whether the intermediary will be subject to reduced rates of Canadian withholding tax in respect of payments received from Canadian parties.
Canada
13 Mar 2009
10
Your Guide To The Transfer Pricing Impact Of The New Canada-US Protocol
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.
Canada
13 Dec 2007
11
Tax Law Bulletin - New Protocol To The Canada-US Tax Treaty: Corporate Continuance And Residence
The Fifth Protocol (the “Protocol”) to the Canada-US Income Tax Convention (the “Treaty”) introduces significant changes to the rules relating to corporate continuance and residence.
Canada
2 Nov 2007
12
Tax Law Bulletin - New Protocol To The Canada-US Tax Treaty: Recognition Of LLCs And Elimination Of Treaty Benefits For Certain Hybrid Entities
On September 21, 2007, Canada and the United States signed the long-awaited Fifth Protocol (the “Protocol”) to the Canada-US Income Tax Convention (the “Treaty”).
Canada
2 Nov 2007
13
Tax Law Bulletin – New Protocol To The Canada-US Tax Treaty: Trans-Border Pension Provisions And New Stock Option Apportionment Rules
The recently released Fifth Protocol (the “Protocol”) to the Canada-US Income Tax Convention (the “Treaty”) significantly expands the scope of the Treaty provisions dealing with pensions.
Canada
30 Oct 2007
14
Tax Law Bulletin - New Protocol To The Canada-US Tax Treaty: Withholding Tax On Cross-Border Payments
Canada and the United States signed the widely anticipated Fifth Protocol (the “Protocol”) to the Canada-US Income Tax Convention (the “Treaty”) on September 21, 2007.
Canada
30 Oct 2007
15
New Protocol To Canada-U.S. Tax Treaty – Elimination Of Withholding Tax On Interest And Other Changes
Canada and the United States signed the widely anticipated 5th protocol to the Canada-U.S. Tax Treaty today. Once it has been ratified by both countries, the Protocol will ultimately eliminate withholding tax on conventional interest payments made by Canadian taxpayers to U.S. residents.
Canada
 
2 Oct 2007
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