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Rosen & Associates
Navigating the intricate realm of taxes can be intimidating for young adults and students in Canada. However, comprehending tax obligations...
Rotfleisch & Samulovitch P.C.
John Tavares, NHL all-star and Captain of the Toronto Maple Leafs, is used to making headlines. Since signing with the Leafs in 2018, Tavares led the Leafs to their first second-round playoff appearance in nearly two decades...
Osler, Hoskin & Harcourt LLP
On February 19, 2024, the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) released a report on Amount B (Amount B Report) that provides guidance on the simplified...
Sorbara Law
When software companies license or "sell" into Canada from abroad, there is often some leeway in how they allocate their fees between the license itself and related services.
Rotfleisch & Samulovitch P.C.
When a taxpayer ceases to be a Canadian tax resident, paragraph 128.1(4)(b) of Canada's Income Tax Act deems the taxpayer to have disposed of almost all property (including cryptocurrency, non-fungible tokens (NFTs), and other digital assets) at fair market value.
Osler, Hoskin & Harcourt LLP
Canada's allure as a global luxury retail destination remains unwavering. With its stable political, economic and financial system...
McMillan LLP
I recently attended the annual National Business Aviation Association conference where I had the opportunity to catch up with my non-Canadian contacts in business aviation.
Rotfleisch & Samulovitch P.C.
A registered charity in Canada is exempt from tax on taxable income if it meets the definition of a charity under section 149.1(1) of the Income Tax Act (the "Act").
Rotfleisch & Samulovitch P.C.
When a taxpayer ceases to be a Canadian tax resident, paragraph 128.1(4)(b) of Canada's Income Tax Act deems the taxpayer to have disposed of almost all property (including cryptocurrency, non-fungible tokens, and other digital assets) at fair market value.
Aird & Berlis LLP
The Canada Revenue Agency ("CRA") has been steadily increasing the intensity of audits targeting cross-border investment and business activity.
MLT Aikins LLP
Payments to non-residents for services rendered in Canada can have major tax implications for both the payor and the service provider. In particular, payors and service providers should be aware of Regulation 105...
Fasken
Certain federal and provincial tax considerations are relevant when one is conducting business in Canada. While Canadian residents are subject to tax on worldwide...
WeirFoulds LLP
A number of issues can arise if an employee of a non-Canadian employer comes to Canada to work remotely. Unless the employee is seconded to a Canadian...
Osler, Hoskin & Harcourt LLP
On July 11, 2023, the OECD/G20 Inclusive Framework on BEPS approved a four-part Outcome Statement on the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation...
Aird & Berlis LLP
From its earliest days, Canada has been a nation focused on international trade – a characteristic that continues today. In 2021, Canadian exports of goods and services...
Lawson Lundell LLP
Canada has a series of bilateral tax treaties. These have evolved over time to include various anti-avoidance, and anti-treaty shopping rules.
Gowling WLG
The March 28, 2023 Federal Budget proposed numerous measures previously discussed in our Firm commentary, prepared on Budget night. This article expands on our initial analysis of the proposed amendments to the GAAR.
Rotfleisch & Samulovitch P.C.
Under subsection 128.1(4) of the Canadian Income Tax Act, a Canadian emigrating to another jurisdiction is subject to a "deemed disposition" on qualifying property.
KPK Law LLP
Agreements for the avoidance of double taxation are bilateral Conventions (herein, sometimes referred to as "treaties") between sovereign States.
Herbert Smith Freehills
In Royal Bank of Canada v HMRC [2023] EWCA Civ 695, the Court of Appeal upheld the taxpayer's appeal in a case relating to the interpretation of the UK-Canada double tax treaty (the "Treaty").
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