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By Sunita Doobay, B.A., LL.B., LL.M. (NYU), TEP
IRC section 267A, added December 2017, denies a deduction to a US-situated payer of interest or a royalty to a related non-US hybrid party or as part of a hybrid transaction.
By Bobby Solhi
The ruling reflects that deemed trust rules are "quite strict," and should be a warning to lenders to investigate a borrower's existing tax obligations, Toronto sales tax specialist Simon Thang said June 12.
By Bobby Solhi
The Crown, on behalf of the CRA, sued TD Bank to recover money that it received from one of its customers.
By Bobby Solhi
Financial services are generally an exempt supply for which no GST/HST would be charged.
By Vern Krishna
Fresh off the press! Volume 2 of Fundamentals of Canadian Income Tax by Vern Krishna has now been published.
By TaxChambers LLP
With all the excitement concerning the price of cryptocurrencies, individuals and businesses have glossed over the fact that every cryptocurrency transaction is a taxable event that also has revenue...
By Bobby Solhi
Recent coverage of the U.S. Supreme Court hearing in South Dakota v. Wayfair, Inc. has brought attention to the issue of sales tax on internet sales.
By Vern Krishna
International tax treaties generally tax income from business on a net basis. This contrasts with the taxation of investment income, which is taxed on a gross basis.
Quebec lost $270 million in 2017 from uncollected sales tax on property and services purchased online, according to the proposal.
By Vern Krishna
Bitcoin, writes Vern Krishna, is "a multi-faceted, highly technical and difficult to trace asset that may quite possibly be a pyramid scheme."
By TaxChambers LLP
Bobby Solhi of TaxChambers LLP was quoted by Bloomberg BNA International Tax Monitor on the recent Tax Court of Canada decision in Jayco, Inc. v. The Queen that addressed GST/HST...
By Vern Krishna
Tax law is driven by policy. Every rule has an underlying rationale, which is purportedly translated into legislative language in the statute.
By Vern Krishna
The federal budget of Feb. 27, 2018, (the Budget), robs Peter to pay Paul by changing the landscape for professionals who use private corporations to structure their businesses.
By Vern Krishna
Cryptocurrency taxation is front of mind for many Canadian investors.
By TaxChambers LLP
The taxation of multinational enterprises (MNEs) is of significant concern as countries are increasingly concerned with the erosion of their taxable base through profit shifting from high tax to low tax jurisdictions.