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Tax Treaties
Aird & Berlis LLP
The Federal Court of Appeal in Alta Energy1 held that the Appellant, a Luxembourg corporation, could properly rely on the Canada-Luxembourg Treaty.
Torys LLP
On February 12, the Federal Court of Appeal (FCA) released its decision in The Queen v. Alta Energy Luxembourg S.a.r.l.1 (Alta Energy),
Osler, Hoskin & Harcourt LLP
The OECD has been working on a two-pillar approach to international tax reform: (a) Pillar One...
TaxChambers LLP
As we commence the new year (2020), we prepare ourselves for what awaits us: spring showers, flowers, and the hand of the tax collector reaching into our pockets.
Davies Ward Phillips & Vineberg
In a case argued by Davies, the Court of Québec rendered a judgment on December 10 setting out, for the first time, the conditions that must be met for the electronic disclosure of evidence by the Crown to be "reasonably accessible", ...
McLennan Ross LLP
Typically, foreign nationals require Work Permits before they can conduct any work in Canada. However, where a foreign national is entering Canada to perform international business activities...
Osler, Hoskin & Harcourt LLP
Earlier in 2019, the OECD published its Programme of Work to Develop a Consensus Solution to the Tax Challenges Arising from the Digitalization of the Economy (Program of Work), ...
Rotfleisch & Samulovitch P.C.
Taxation has become an increasingly global issue as people, money and property move freely across borders.
Osler, Hoskin & Harcourt LLP
Earlier in 2019, the OECD published its Programme of Work [PDF] to Develop a Consensus Solution to the Tax Challenges Arising from the Digitalization of the Economy (Program of Work)
Minden Gross LLP
This paper will discuss a limited selection of Canadian income tax issues arising in estate administration1 as follows.
Blaney McMurtry LLP
2019 by the American Bar Association. Reprinted with permission. All rights reserved. This information or any or portion thereof may not be copied or disseminated in any form ...
Rotfleisch & Samulovitch P.C.
To many people, an unlimited liability company (ULC) may sound like a contradiction in terms.
Bennett Jones LLP
On August 29, 2019, Canada completed its domestic ratification of the OECD-sponsored Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting
McMillan LLP
On June 7, 2017, Canada along with numerous other jurisdictions signed the Organisation for Economic Co-operation and Development's
Rotfleisch & Samulovitch P.C.
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.
Rotfleisch & Samulovitch P.C.
Emigrating from Canada has a multitude of tax implications including which country can tax particular income and the Canadian tax owed for emigrating.
McMillan LLP
On May 31, 2019, as one of the main areas of focus of the ongoing work on the Base Erosion and Profit Shifting ("BEPS") project, Members of the OECD/G20 Inclusive Framework on BEPS ("Framework")
Davies Ward Phillips & Vineberg
Canada is expected to notify the OECD within the next few months that it has ratified the MLI.
Blaney McMurtry LLP
When asking a U.S. tax adviser to describe the "revenue rule," it would not be surprising for the adviser to say that it refers to formal guidance issued by the I.R.S. that can be relied on by...
In February and March of 2019, the OECD organized a public consultation process, releasing a consultation document on February 13, 2019, inviting public comments up until March 6, 2019, and holding a conference where industry...
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