Searching Content indexed under Tax Treaties by McCarthy Tétrault LLP ordered by Published Date Descending.
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MLI Big Picture Changes Update
Assuming the bill receives Royal Assent, Canada will then deposit a notice of ratification with the MLI depository
30 Nov 2018
2017 Canadian Federal Budget Commentary – Tax Initiatives
On March 22, 2017 (Budget Day), Finance Minister Bill Morneau tabled in the House of Commons the Liberal Government's second budget, Building a Strong Middle Class (Budget 2017).
23 Mar 2017
2016 Canadian Federal Budget Commentary – Tax Initiatives
On March 22, 2016 (Budget Day), Finance Minister Bill Morneau tabled in the House of Commons the new Liberal Government's first budget, Growing the Middle Class (Budget 2016).
4 Apr 2016
Anson V. HMRC: Another Approach To LLCs
The facts in the case may be summarised as follows. The taxpayer in the case (Anson) was a non-domiciled UK resident and member of an LLC which carried on the business of managing venture capital funds in the US.
4 Dec 2015
BEPS Final Reports: An Update On Treaty Shopping
The Organisation for Economic Co-operation and Development (OECD) sees treaty shopping as an important source of Base Erosion and Profit Shifting.
3 Dec 2015
Proposed Relieving Measure For Regulation 102 Withholdings By Non-Resident Employers
The ultimate tax liability of the employee will not be affected if the employee is not, in fact, entitled to treaty benefits in respect of the remuneration.
9 Jul 2015
Treaty Shopping Update
Treaty shopping has received a great deal of attention in Canada in recent years.
9 Jul 2015
Fourth Protocol To Canada-UK Treaty Eliminates Withholding Tax On Arm’s Length Interest, But Preserves Tax Exemption For Gains On Disposition Of Shares And Interests Deriving Value From Canadian Real Property
Canada and the UK signed the fourth protocol amending the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland.
16 Oct 2014
Treaty Shopping Proposals – A Review Of 2013 And 2014 Developments
In Budget 2013, the Government announced its intention to consult on possible measures to combat treaty shopping.
9 May 2014
Velcro Canada Inc. v. The Queen: Riding Prévost Car To Victory
In the tax world, "treaty-shopping" occurs when a person resident in Country A organizes a legal entity in, and directs income through, Country B, solely to secure benefits under a tax treaty between Countries B and C that would not be available to a resident of Country A, typically preferential tax treatment for income sourced from Country C.
12 Apr 2012
End Of The "Address Rule" For Determining Withholding On Payments To Non-Residents — Extension Of Transitional Period Announced
In our earlier update, "New Developments in Canadian Withholding Tax Obligations — New Forms Signal the End of the "Address Rule"," we discussed the change from the Canada Revenue Agency's previous position that generally accepted the use of the payee's name and address for determining whether to apply treaty benefits
17 Jan 2012
Canada-Barbados Tax Treaty - New Protocol
On November 8, 2011, a new protocol (Protocol) amending the Canada-Barbados Income Tax Agreement (Treaty) was signed by the two countries, updating the Treaty to conform with current tax treaties and to reflect Canada’s commitment to promote exchange of tax information in accordance with OECD standards.
17 Jan 2012
Payments To Non-Resident Financial Intermediaries — Update On Canadian Withholding Tax Obligations
The Canada Revenue Agency (CRA) has amended its administrative position on Canadian withholding tax obligations on payments of interest, dividends, royalties, etc., to non-residents to be effective on January 1, 2012 (now extended to January 1, 2013).
16 Jan 2012
Foreign Affiliate Proposals - Some Welcome And Unwelcome Changes
On August 19, 2011, the Department of Finance (Finance) released extensive proposed amendments (2011 Proposals) to the foreign affiliate rules which, in some cases, replace a number of the more controversial amendments that were contained in the proposed amendments released on February 27, 2004 (2004 Proposals) and that may be viewed as a significant shift in tax policy.
16 Sep 2011
Section 116 Clearance Certificates: Relief For Treaty-Exempt And Treaty-Protected Property
A non-resident of Canada is generally taxable under the Income Tax Act (Canada) (Act) on any income or gains arising on the disposition of taxable Canadian property (TCP), except where the non-resident is entitled to a treaty exemption.
4 May 2011
US LLCs May Claim Refunds in Certain Circumstances
The Canada Revenue Agency (CRA) recently announced that it will accept claims for treaty benefits by US limited liability companies (LLCs) in certain circumstances.
4 Nov 2010
Relief for Non-Residents of Canada on Canadian Property Dispositions
Budget 2010 proposes significant changes to Canada’s international tax rules. Effective for dispositions after March 4, 2010, the liability for Canadian tax on gains from the disposition of Canadian investments will be eliminated in many cases, together with the reporting and withholding requirements, enhancing the ability of Canadian businesses to attract foreign venture capital.
5 May 2010
OECD Releases Report on Improving Procedures for Tax Relief for Cross-Border Investors
On February 8, 2010, the Organisation for Economic Co-Operation and Development (OECD) released a public discussion draft of a report entitled "Possible Improvements to Procedures for Tax Relief for Cross-Border Investors: Implementation Package."
5 May 2010
US LLCs — Limited Opportunity?
The April 8, 2010 decision of the Tax Court of Canada in "TD Securities (USA) LLC v. R." (2008-2314(IT)G) has reversed a long-standing position of the Canada Revenue Agency (CRA) that US limited liability companies (LLCs) are not entitled to the benefits of the "Canada-US Income Tax Convention" (Treaty) before the recent amendments made in the Fifth Protocol to the Treaty.
4 May 2010
2010 Federal Budget Commentary
Following the resumption of Parliament, the minority Harper government released its fifth Budget on March 4, 2010 (Budget 2010). The focus of Budget 2010 is to continue to support economic growth, jobs, infrastructure and industry.
9 Mar 2010
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