Canada: Tax Treaties

Permanent establishment Canada analysis has become increasingly complex due to the OECD’s 2025 remote work guidance. Remote work permanent establishment Canada risk is now a central concern for businesses operating across borders and provinces.

Colombian superstar Shakira has secured an important win against Spanish tax authorities. Spain’s High Court cleared her of tax fraud charges for the 2011 tax year and directed the government to repay over US$64 million in fines and interest.

Canadians who own US property, hold American investments, or have family members with US citizenship face a complex web of estate tax obligations spanning two countries. Without proper coordination, your heirs could face double taxation, frozen assets during lengthy Florida probate proceedings, or unexpected tax bills that consume a significant portion of their inheritance.

Many Canadians dream of owning a vacation property in the United States, whether it is a condominium in Florida, a cottage in Vermont, or a ski chalet in Colorado, U.S. situs property represents both lifestyle and investment value.

The Tax Court of Canada's decision in ExxonMobil Canada Resources Company v R addresses the deductibility of $36 million in feasibility study costs for the Alaskan Gas Pipeline Project, examining whether transfer pricing rules apply to adjust or deny the deduction. The case explores critical questions about source of business income, arm's length transactions between related parties, and the application of Part XIII non-resident withholding tax in the context of cross-border pipeline development ventures.

Every year, as June 15 rolls around, hundreds of thousands of Americans living abroad receive the same unwelcome reminder: it's time to file US taxes again.

For professional athletes, life off the field or rink can be just as complex as it is on it, especially when it comes to understanding taxes.

Determining whether you are a resident of Canada for tax purposes is a critical first step in ensuring compliance with Canadian tax laws.

The Canada Revenue Agency (CRA) is setting its sights on the multi-million-dollar contracts of professional athletes playing for Canadian sports teams, scrutinizing whether certain "signing bonuses" were truly inducements to sign, or simply regular compensation disguised as such.