Tax Law and International Tax Law

Cyber‑enabled cargo theft is a modern form of freight theft in which criminals use digital impersonation, stolen credentials and system manipulation to fraudulently obtain cargo...

The Autumn Budget contained a range of pensions-related announcements with implications for employers and trustees of all occupational pension schemes.

The Chancellor has today announced her highly anticipated autumn Budget.

The recent decision in C&W Offshore Ltd. v. HMK, 2026 TCC 40, serves as a stark reminder to Canadian businesses of the rigorous obligations imposed by Part XIII of the Income Tax Act (ITA) when dealing with non-resident suppliers.

Understanding foreign tax credits is essential for taxpayers with international income. This analysis examines the qualification criteria for creditable foreign taxes, the basket system that limits cross-crediting across income categories, and the procedural requirements for claiming these credits on U.S. tax returns.

On a motion to approve a holdback release order in One Bloor West Toronto Group (The One) Inc. (Re), (“One Bloor West”), the Ontario Superior Court of Justice (the “Court”) exempted the Monitor and chief restructuring officer from liability under certain tax legislation regarding the tax and withholding obligations of taxpayers’ representatives on distributions.

The perception that Internal Revenue Service enforcement is stronger than Canada Revenue Agency enforcement is common among taxpayers and advisors, particularly in cross-border contexts.

Permanent establishment Canada analysis has become increasingly complex due to the OECD’s 2025 remote work guidance. Remote work permanent establishment Canada risk is now a central concern for businesses operating across borders and provinces.

The recent decision in C&W Offshore Ltd. v. HMK, 2026 TCC 40, serves as a stark reminder to Canadian businesses of the rigorous obligations imposed by Part XIII of the Income Tax Act (ITA) when dealing with non-resident suppliers.

In 2026, the federal tax treatment of export income undergoes a structural shift as FDDEI replaces FDII, eliminating the qualified business asset investment limitation and revising expense allocation rules.

Transfer pricing complexities emerge as artificial intelligence systems increasingly rely on vast training datasets, raising critical questions about how multinational corporations should value and allocate these intangible assets across jurisdictions. The intersection of AI development and international tax law presents novel challenges for determining arm's length pricing when data crosses borders within corporate structures.

Navigate the complexities of Canadian transfer pricing audits with expert guidance on documentation requirements, CRA audit powers, and privilege protection. Learn strategic approaches to functional interviews, information requests, and compliance obligations while understanding the consequences of non-compliance and proposed legislative changes that could significantly impact audit procedures.