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Rotfleisch & Samulovitch P.C.
Gone are the days when offshore bank accounts were outside the CRA's reach. With the advent of the CRS, CRA automatically receives financial information of Canadian taxpayers who own bank accounts or assets in other jurisdictions.
Rotfleisch & Samulovitch P.C.
The facts and a detailed analysis by our skilled Canadian tax lawyers follows on this watershed case.
KPK Law LLP
The CRA emphasized that there are more tax evasion investigations to come while also setting out the serious consequences of tax evasion in Canada.
Norton Rose Fulbright Canada LLP
The April 2016 "Panama Papers" leak highlighted the attraction for transnational actors of the confidentiality available in certain offshore financial centres.
KPK Law LLP
Sunita Doobay of TaxChambers LLP discusses the use of a Canadian LP to shield a non-resident's assets in her latest article for Canadian Tax Highlights.
Crowe MacKay LLP
The ITA contains rules (the FAPI rules) that are intended to tax investment income earned by a "controlled foreign affiliate" of a Canadian taxpayer when it is earned...
Devry Smith Frank LLP
Toronto Tax Lawyer Sabina Mexis discussed a CBC/Toronto Star investigation which looked into Canada's tax system...
Collins Barrow National Incorporated
The current acceptance procedure does not require the taxpayer to pay any such amounts on filing and not doing so does not preclude the acceptance of the disclosure.
Collins Barrow National Incorporated
In recent months, there have been rumblings that the Streamlined program – a "friendly" system that helps U.S. taxpayers living abroad get caught up on their filing obligations – is coming to an end.
Dentons
The Offshore Compliance Advisory Committee (OCAC) has published its report on the CRA's Voluntary Disclosure Program...
Rotfleisch & Samulovitch P.C.
CRA has announced that it's increasing the number of international electronic funds transfers (EFT) tax audits that it will be conducting.
Stikeman Elliott LLP
Although based in low-tax jurisdictions, Tax Court finds business reasons for investments overshadowed their tax benefits.
Rotfleisch & Samulovitch P.C.
In what is becoming a familiar headline, the Washington-based International Consortium of Investigative Journalists has announced another leak of offshore tax haven information.
Stikeman Elliott LLP
On July 22, 2016, the Tax Court of Canada released its highly anticipated decision in Gerbro v. R dealing with the offshore investment fund property rules in section 94.1 of the Income Tax Act.
Grant Thornton
In October 2015, OECD released its BEPS Action 13, focused on new country-by-country (CbC) reporting requirements for large multinational enterprises (MNEs).
Rotfleisch & Samulovitch P.C.
The Offshore Tax Informant Program (OTIP) is the Canada Revenue Agency (CRA) confidential whistleblower program that was put in place in January 2014.
Collins Barrow National Incorporated
It seems that every day now there is an article of some sort addressing aggressive tax structures, often utilizing offshore entities, and the ramifications of (implied) inappropriate, underlying transfer pricing policies.
Cassels
Kingsway Financial Services Inc. v. Kobex Capital Corp. is noteworthy in emphasizing that, when determining whether a take-over bid has occurred, joint actor status is fact dependent and must relate to the take-over bid.
Borden Ladner Gervais LLP
Most are not impacted and read them out of curiosity. However, for some Canadian residents, there may be cause for concern, but also, a solution.
KPK Law LLP
On April 8, 2016, a UK-Cayman Islands exchange of notes was signed regarding the sharing of beneficial ownership information.
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