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Searching Content indexed under Tax Treaties by Rotfleisch & Samulovitch P.C. ordered by Published Date Descending.
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Income Tax For Canadians Working At Sea – A Canadian Tax Lawyer's Perspective
If you are a Canadian citizen or resident working or planning to work at sea, then it may seem counterintuitive to learn that the income you earn from that job will be subject to Canadian income tax as though it was earned here in Canada.
Canada
26 Aug 2019
2
A Canadian Tax Lawyer's Perspective On Emigration Tax Issues
Emigrating from Canada has a multitude of tax implications including which country can tax particular income and the Canadian tax owed for emigrating.
Canada
20 Aug 2019
3
Case Comment – MNR v Roofmart Ontario Inc. ("Roofmart")
The CRA has general powers to require persons to provide information related to a tax audit however these general powers are limited, such that, the CRA cannot require persons to provide third party documents without judicial authorization.
Canada
4 Jul 2019
4
Canadian Snowbirds Should Know These US Tax Residence Rules – Tips from A Canadian Tax Lawyer
If none of the factors are conclusive which is a very rare situation, you must ask the competent authority of each country to make a decision.
Canada
18 Jun 2019
5
Back-To-Back (B2B) Loans – Withholding Tax Rates On Interest, Rents, And Royalties
For individuals or corporations that are not tax residents in Canada, certain payments that they receive from Canadian sources are subject to withholding taxes.
Canada
15 Jan 2019
6
Limited Liability Corporation
Various tax efficient vehicles are available to Canadians who purchase and hold assets, or carry out business in the United States.
Canada
12 Nov 2018
7
Part-Year Residence
Your status as a tax resident determines the extent to which Canada may tax your income. Canada taxes its residents on their worldwide income.
Canada
8 Nov 2018
9
Multilateral Convention To Implement Tax Treaty Related Measures To Prevent Base Erosion And Profit Shifting (BEPS MLI) Signed
Earlier in June 2017 68 members of the OECD signed a tax treaty that has the effect of amending bilateral tax treaties on a wholesale basis.
Canada
20 Jun 2017
10
Canada – Switzerland Bank Information Exchange
The Swiss Consulate in Canada has been writing to Swiss residents of Canada to advise them of the information exchange agreement between Canada and Switzerland.
Canada
22 Mar 2017
11
SCC Update On Tax Rectification
Part III of this Toronto tax lawyer tax rectification article discusses the Supreme Court of Canada's decision and its tax planning implications.
Canada
8 Mar 2017
12
Ongoing Panama Papers Leak CRA Tax Audits
On January 16 and 17, 2017 CRA participated in a meeting of the Joint International Taskforce on Shared Intelligence and Collaboration Network (JITSIC), a network of over 35 tax administrations.
Canada
14 Feb 2017
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