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1
Transfer Pricing: What's New In Canada (Part II)
In Part I of this article,[1] we provided an overview of transfer pricing developments in Canada since the start of the Organization for Economic Cooperation and Development's
Canada
4 Sep 2019
2
Transfer Pricing: What's New In Canada (Part I)
Since 2012, there have been unprecedented developments in Canada and globally in the area of international tax. The sheer volume and complexity
Canada
5 Aug 2019
3
Budget 2019 : Positionnement en vue des élections d'automne
Les taux marginaux d'imposition les plus élevés du Canada étant décrits par certains analystes comme étant « punitivement élevés » et l'économie canadienne glissant vers un taux de croissance annualisé de seulement ...
Canada
21 Mar 2019
4
Budget 2019: Positioning For A Fall Election
With Canada's top marginal tax rates described by some analysts as "punitively high," and with the Canadian economy sliding to an annualized rate of growth of only 0.4 per cent in the fourth quarter, many were hoping for tax reductions in Budget 2019 that would help make Canada more competitive.
Canada
21 Mar 2019
5
Budget 2018: Sensible Measures
From a tax perspective, the headline news is that Budget 2018 completes the Government of Canada's general retreat from the astounding July Proposals to address passive investment income in private corporations.
Canada
28 Feb 2018
6
Ten Important Canadian Tax Compliance Considerations For New Canadians
Even prior to the postal code project, which focuses on any potential high net worth individual...
Canada
4 Dec 2017
7
Proposed Foreign Merger Rollovers Rules: Welcome News To Foreign Companies That Cannot Rely On Existing Tax Treaty Rollover Provisions
On October 27, 2017, under Bill C-63, the Department of Finance released proposed amendments to the Income Tax Act (Canada) ("ITA") introducing a new elective rule allowing non-residents tax-deferred ...
Canada
21 Nov 2017
8
The Sifto Decision — Is The Minister Bound By MAP Settlements?
On March 10, 2017, the Tax Court of Canada ("TCC") delivered its decision in Sifto Canada Corp. v. The Queen1 regarding the legal effect of a transfer pricing settlement reached under the Mutual Agreement...
Canada
22 May 2017
9
Le Budget 2017 : Pas De Grands Changements Dans Un Budget Attentiste
Malgré le déficit qui ne cesse d'augmenter, le budget 2017 ne contient aucune augmentation de taxe générale ou autres mesures qui pourraient changer la donne, lesquelles mesures...
Canada
23 Mar 2017
10
Budget 2017: No Game-Changers In Holding-Pattern Budget
Despite rising deficits, Budget 2017 does not propose any general tax increases or other game-changing measures that were the subject of much speculation in recent weeks.
Canada
23 Mar 2017
11
Changes Coming To Country-By-Country Transfer Pricing Documentation Requirements
Businesses with international operations need to be aware of changes to the required transfer pricing documentation that will apply in the near future.
Canada
30 Aug 2016
12
Federal Budget 2016 — Incremental, Not Fundamental Tax Changes
On March 22, 2016 the Minister of Finance tabled Budget 2016, the first budget of the current government's mandate.
Canada
23 Mar 2016
13
The "Marzen" Decision: A typical Example Of BEPS
On June 10, 2014, the Tax Court of Canada delivered its most recent decision on transfer pricing, one which involved a Barbados structure.
Canada
14 Oct 2014
15
Conrad Black: Resident Here, Resident There, Resident Everywhere?
It is common for an individual to be resident in more than one country at a given time (i.e., to be a "dual resident").
Canada
25 Mar 2014
16
Le budget de 2014 – objectif : intégrité
Le ministre des Finances Jim Flaherty s’enorgueillit du nombre de mesures d’intégrité qu’il a introduites depuis 2006.
Canada
12 Feb 2014
17
Budget 2014: Fiscal Integrity As A Work In Progress
Minister of Finance Flaherty takes pride in the integrity measures he has introduced since 2006. Last year, Budget 2013 touted over 75 measures aimed at improving integrity and closing tax loopholes
Canada
12 Feb 2014
18
New Limitation On Benefits Provisions In Canada’s Tax Treaties – A Step Too Far?
Canada’s tax treaties with foreign countries routinely include a variety of anti-abuse or treaty shopping provisions aimed at those structures or transactions utilized to improperly access treaty benefits.
Canada
22 Jul 2013
19
Federal Budget 2013: How Will It Impact Your Business?
On February 6, 2013 the Honourable Jim Flaherty celebrated his seventh anniversary as Canada’s Minister of Finance, and on Thursday March 21, 2013 he delivered his eighth federal budget.
Canada
8 Apr 2013
20
Federal Budget 2013: How Will It Impact Your Business? - Integrity Measures
Budget 2013 contains a large number of "integrity" measures, including "tightening" measures and reporting and penalty measures.
Canada
25 Mar 2013
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