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Searching Content indexed under Tax Treaties by Jim Wilson ordered by Published Date Descending.
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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
2
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
3
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
4
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
5
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
6
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
7
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
8
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
9
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
10
Canada's New Tax Treaty With Hong Kong: 10 Key Aspects
On Nov. 11, 2012, after relatively swift negotiations, the Government of Canada signed a tax treaty with the Government of the Hong Kong Special Administrative Region of China and it will provide tax relief for residents of both jurisdictions and, more importantly, could encourage inbound investments to Canada from Hong Kong.
Canada
24 Jan 2013
11
Permanent Establishments - Canadian Update
The determination of whether a permanent establishment (PE) exists in Canada has always been the subject of confusion and uncertainty for non-resident taxpayers doing business or contemplating doing business in Canada.
Canada
7 Dec 2012
12
Small Business Taxation @ Gowlings - September 12, 2011
The Canada Revenue Agency ("CRA") recently issued the first Canadian Advance Income Tax Ruling ("ATR")[1] regarding whether a non-resident corporation ("NRco") has a permanent establishment ("PE") in Canada where part of its business activities have been sub-contracted to its wholly-owned subsidiary in Canada ("Canco") (the "Ruling").
Canada
20 Sep 2011
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