With
Jeffrey Shafer
The Fifth Protocol (the Protocol) to the Canada–U.S. Income Tax Convention (the Treaty) introduced bilateral limitation on benefits (LOB) provisions.
With
Sarah Davidson Ladly
On July 15, 2008, the Federal Court of Canada released its decision in the case of “FMC Technologies Company v. Minister of National Revenue”.
With
Bryan Bailey,
Leslie Morgan
The Technical Explanation (TE) offers welcome interpretation of the new rules in the Fifth Protocol (the Protocol) to the Canada-United States Income Tax Convention (the Treaty) relating to hybrids and fiscally transparent (flow-through) entities.
With
Edward Miller
When Canadian companies license computer software from U.S.
licensors and arrange for maintenance and support services for
the software, there are a number of Canadian tax issues to
consider.
With
Chris Van Loan
On April 22, 2008, the Honourable Gerald J. Rip, Associate
Chief Justice of the Tax Court of Canada, released his decision
in the case of Prévost Car Inc. v. The Queen
The Canada Revenue Agency (CRA) has recently issued an administrative income tax ruling which expands the possible application of the 5/25 Canadian withholding tax exemption for interest paid by Canadian corporate borrowers, by blessing a back-to-back loan arrangement.
In the course of an audit, the Canada Customs and Revenue Agency (CCRA) has the ability to require a taxpayer’s accountants and lawyers to provide documents and information in their possession. CCRA’s rights are not unrestricted and, in several recent cases, the scope of the protection of documents from disclosure on the grounds of solicitor-client privilege has been tested
