Mondaq Canada: Tax
KPMG
La Cour de l'impôt a confirmé que le contribuable pouvait déduire 6 214 288 $ de bonus ou gratification payés à ses employés sous forme d'actions émises du trésor.
Torys LLP
The OECD released its first Base Erosion and Profit Shifting recommendations to the OECD and G20 countries to combat tax avoidance by multinational enterprises.
Davies Ward Phillips & Vineberg
IRS Notice 2014-52 includes broad new rules designed to increase the tax cost of U.S. corporate inversions and reduce opportunities to lower global effective tax rates.
Miller Thomson LLP
The Department of Finance released revised anti-avoidance back-to-back loan arrangement proposals ("August 2014 Draft Proposals").
Cassels Brock
A failure to fully appreciate and mitigate the potential withholding tax risks can have significant adverse tax and cash flow implications to the parties.
Collins Barrow National Cooperative Inc.
From time to time, many Canadians find themselves considering a permanent move to the United States.
Osler, Hoskin & Harcourt LLP
OECD released its first seven of 15 deliverables under the OECD/G20 base erosion and profit shifting (BEPS) project (the 2014 BEPS Package).
Dentons (Canada)
In Devon Canada Corporation v. The Queen the issue is whether the taxpayer may deduct $20,884,041 paid to cancel issued stock options.
Minden Gross LLP
Selling a winning stock at current market highs will result in a capital gain. Exactly what you want! Unfortunately, it could also result in a hefty tax bill.
Miller Thomson LLP
When a Canadian resident makes a payment to a non-resident, the Canadian payor is required to withhold 25% in certain circumstances.
McInnes Cooper
The Canadian federal government has been concerned for some time about "treaty shopping" by non-residents.
Lerners
In order to be a "co-operative corporation" for the purposes of the ITA, the corporation must satisfy the requirements set out in section 136(2)(a) of the ITA.
Collins Barrow National Cooperative Inc.
The 2014 Federal Budget introduced legislation to eliminate the graduated rate of taxation for testamentary trusts.
MNP
Over the past six years, the United States has become increasingly concerned that Americans are stashing money offshore, essentially evading U.S. tax.
Dentons (Canada)
In Gariepy v. the Queen, the Tax Court considered whether two directors had effectively resigned from their positions.
MNP
Lately I’ve noticed a number of articles regarding bank accounts held offshore by Canadian residents.
Dentons (Canada)
Justice Patrick Boyle recused himself from the two remaining issues with which he was seized in the transfer pricing case – costs and the content of the court’s public file.
TaxChambers LLP
An appeal was filed with the Federal Court of Canada in Vancouver seeking a declaration that the enforcementof the US FATCA on Canadian soil is unconstitutional.
TaxChambers LLP
In Achim Bekesinski and Her Majesty the Queen, the taxpayer, as director of a corporation, was personally reassessed by the Minister of National Revenue.
Blaney McMurtry LLP
Two recent court decisions provide a vivid reminder that timing obligations are not the taxpayer's alone. The CRA has them, too.
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Moodys Gartner Tax Law LLP
Why would a country with a seven to ten year wait list to acquire citizenship have so many citizens headed for the exit?
MNP
Over the past six years, the United States has become increasingly concerned that Americans are stashing money offshore, essentially evading U.S. tax.
Moodys Gartner Tax Law LLP
Virtually all Canadian snowbirds know they must keep track of how many days they are in the US and outside of Canada because "bad" tax and non-tax surprises await those who are in or out of either country too long.
Minden Gross LLP
We all know the cardinal rule relating to RRSP withdrawals before maturity: DON’T DO IT!
Davies Ward Phillips & Vineberg
Form W-8BEN-E is a critical component of foreign entity compliance with the Foreign Account Taxpayer Compliance Act.
Moodys Gartner Tax Law LLP
In 280 BC the Greek King Pyrrhus won a decisive battle against the Roman army. However in winning the battle, Pyrrhus’s army suffered great losses and when Rome had a chance to reconnoiter, it easily defeated what remained of the Greek’s army.
MNP
The transfer pricing adjustment rules apply when transactions undertaken by non-arm’s length parties do not reflect arm’s length terms and conditions.
McMillan LLP
Budget 2014 proposes a number of changes to the taxation of trusts and estates under the Income Tax Act (Canada) (the "Tax Act") that will have a significant impact on tax planning.
Crowe Soberman LLP
Did you know that the U.S. Department of Homeland Security is now tracking your entrance to and exit from the U.S. by land, sea, and air?
TaxChambers LLP
An appeal was filed with the Federal Court of Canada in Vancouver seeking a declaration that the enforcementof the US FATCA on Canadian soil is unconstitutional.
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