Search
Searching Content indexed under Tax Treaties by Dentons ordered by Published Date Descending.
Links to Result pages
 
1  
 
Title
Country
Organisation
Author
Date
1
FCA Dismisses Lord Black’s Tax Appeal
Further, the Tax Court held that Article 27(2) of the Canada-UK Treaty applied to enable the CRA to assess a Canadian resident’s non-Canadian office and employment income.
Canada
19 Dec 2014
2
Federal Court Of Appeal: Canada Cannot Tax Treaty Income Twice
It is trite law that one of the main purposes of tax treaties is to prevent double taxation of the same income.
Canada
18 Jul 2012
3
Further Thoughts On The Fundy Settlement Decision: Supreme Court Offers A Nuanced View Of Trust Residence
In "Garron Family Trust v. The Queen" (2009 TCC 450), Justice Judith Woods of the Tax Court of Canada came down with a very broad new rule for determining the residence of trusts.
Canada
1 May 2012
4
"Beneficial Owner" – CRA’s Assessment Of Velcro Doesn’t Stick"
The Tax Court has once again considered the meaning of the phrase "beneficial owner" for purposes of the tax treaty between Canada and the Netherlands.
Canada
6 Mar 2012
5
Tower Financing: Deduction Denied
Taxpayers that have implemented cross-border tower financing structures and that have claimed a Canadian tax deduction for any U.S. taxes paid should revisit their structures carefully in light of the Tax Court of Canada’s recent decision in "FLSMIDTH Ltd., v. The Queen" (2012 TCC 3), which is the Court’s first decision concerning tower structures.
Canada
18 Jan 2012
6
Canada Border Services Agency Update: Expecting A Customs Audit?", Focus On Tax, June 2011
The Canada Border Services Agency (CBSA) has recently released its 23 "target" national audit priorities for the coming year.
Canada
9 Aug 2011
7
The Century Services Case - Getting The Crown's Priorities Straight
The decision of the Supreme Court of Canada last month in Century Services Inc. v. Canada is of striking interest to the tax and insolvency bars
Canada
4 Mar 2011
8
378 Days To Victory: The Conduct Of A Ground-Breaking Tax Treaty Case, Knights Of Columbus v. R.
On Friday June 13, 2008, multinational enterprises doing business in Canada finally received greater tax certainty in respect of their cross-border operations.
Canada
9 Jul 2008
Links to Result pages
 
1