Searching Content indexed under Tax Treaties by Blake, Cassels & Graydon LLP ordered by Published Date Descending.
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From Israel To Canada: New Tax Treaty To Help Structure Investments
On December 21, 2016, the new Canada–Israel tax treaty entered into force.
30 Jan 2017
2016 Federal Budget – Selected Tax Measures
On March 22, 2016, the Minister of Finance tabled Canada's 2016 Federal Budget (the 2016 Budget).
4 Apr 2016
Canada And U.K. Agree To Protocol To Amend Tax Treaty
On July 21, 2014, a protocol to amend the Canada-U.K. tax treaty was signed in London, England. Negotiations to update the Treaty had been ongoing since 2011.
23 Jul 2014
Canadian Government Introduces Treaty Shopping Consultation Paper
In the March 2013 Canadian federal budget, the Minister of Finance announced an intention to consult on possible measures to "protect the integrity of Canada's tax treaties while preserving a business tax environment that is conducive to foreign investment".
20 Aug 2013
Canada Signs Tax Treaty With Hong Kong
On November 11, 2012, the Government of Canada signed a double tax treaty with the Government of the Hong Kong Special Administrative Region of the People's Republic of China.
15 Nov 2012
2010 Canadian Federal Budget Significantly Narrows Taxation Of Non- Residents Investing In Canadian Equity
In its Budget delivered on March 4, 2010, the Government of Canada announced a significant liberalization of Canadian tax laws applicable to foreign investors in Canadian businesses.
11 Mar 2010
2010 Federal Budget
While the lead-up to and the media coverage of the federal budget introduced on March 4, 2010 (the Budget) was heavily skewed towards deficit control, there was no shortage of significant tax proposals in the Budget, including the following:
10 Mar 2010
Department Of Finance Releases Draft Foreign Affiliate Amendments Affecting Acquisitions And Reorganizations
On December 18, 2009, the Department of Finance (Finance) released a package of technical amendments to the foreign affiliate rules (the December 18th Proposals).
13 Jan 2010
Canada Revenue Agency Interprets Anti-Hybrid Rule
The Fifth Protocol to the Canada-U.S. tax treaty (the Treaty) was ratified in December 2008, and for most purposes came into force in 2009. One of the more controversial measures contained in the Protocol is the new "anti-hybrid" rule in Article IV(7) of the Treaty.
1 Dec 2009
Canada Signs Its First Tax Information Exchange Agreement
On August 29, 2009, Canada signed its first tax information exchange agreement (TIEA) with the Netherlands in respect of the Netherlands Antilles (which is specifically not covered by the tax convention between Canada and the Netherlands) (the Netherlands Antilles TIEA).
25 Sep 2009
2009-2010 Quebec Budget Highlights
Quebec Finance Minister Monique Jérôme-Forget tabled the 2009-2010 budget of the Government of the Province of Quebec on Thursday, March 19, 2009 (Budget) not only against the backdrop of a provincial economic recession but also that of a global financial economic crisis.
24 Mar 2009
2009 Federal Budget
With numerous spending initiatives released in the days leading up to the January 27, 2009 federal budget, many wondered whether the tabling of the Budget itself would be anti-climactic.
9 Feb 2009
Changing The Borders - Report Of Canadian Advisory Panel On International Taxation
In the aftermath of the Canadian government’s attempt to restrict the deduction of so-called “double dip” interest, the government established the Advisory Panel on Canada’s System of International Taxation.
29 Dec 2008
Fifth Protocol To Canada - U.S. Tax Treaty Enters Into Force
On December 15, 2008, the Fifth Protocol to the tax treaty between Canada and the United States entered into force.
25 Dec 2008
Permanent Establishment Under Canada–United States Tax Convention Part I – The Knights Of Columbus Decision
On May 16, 2008, two significant decisions of the Tax Court of Canada (the Court) dealing with the interpretation of the meaning of permanent establish¬ment under the Canada–United States Tax Convention (the Convention) were released: “Knights of Columbus v. R., and American Income Life Insurance Company v. R.”.
8 Sep 2008
Technical Explanation Offers Guidance – Mutual Recognition Of Contributions For Pension And Other Retirement Plans But Not On Pension Investment
The Fifth Protocol (the Protocol) to the Canada-United States Income Tax Convention (the Treaty) modifies the Treaty with respect to contributions and benefits under pension plans (or certain other qualifying retire¬ment plans) by and on behalf of individuals residing in one Contracting State and working in the other (Commuters), as well as individuals who move from one Contracting State to the other on short-term (up to five years) work assignments, and continue to contribute to a plan in the f
21 Jul 2008
Technical Explanation To Protocol Offers Limited Guidance On Limitation On Benefits
Under prevailing U.S. tax treaty policy, newly negotiated or renegotiated U.S. tax treaties must contain “limitation on benefits” (LOB) rules.
21 Jul 2008
Arbitration Provision Takes Aim At Competent Authority Deadlock
Where a taxpayer considers that the assessing actions of one of the Contracting States to the Canada-U.S. Income Tax Convention (the Treaty) will result in double taxation, the taxpayer may present its case to the competent authority of the Contracting State of which the taxpayer is a resident.
21 Jul 2008
An Introduction To The Technical Interpretation To The Fifth Protocol To The Canada-United States Income Tax Convention
The Fifth Protocol (the Protocol) to the Canada-United States Income Tax Convention (the Treaty) was released with much fanfare on September 21, 2007. Canada and the U.S. have independently entered into a multitude of bilateral tax treaties that tend to follow the Organisation for Economic Co-operation and Development (OECD) Model Tax Convention.
18 Jul 2008
Changes To And Elimination Of Withholding Tax On Interest And Guarantee Fees
The Technical Explanation (TE) provides commentary and some welcome clarification on the withholding tax exemptions to be provided by the Fifth Protocol (the Protocol) to the Canada-United States Income Tax Convention (the Treaty) on cross-border interest and guarantee fee payments, and the timing of this relief.
18 Jul 2008
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