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Searching Content indexed under Tax Treaties by Osler, Hoskin & Harcourt LLP ordered by Published Date Descending.
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1
Impact Of Recent International Tax Developments On Canada
Recent international tax changes proposed by the OECD could significantly impact the cross-border activities of Canadians – particularly with respect to tax planning strategies that shift profits to low or no-tax jurisdictions.
Canada
5 Jul 2019
2
Update On Implementation Of The Multilateral Instrument In Canada
Canada signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting [PDF] ― also known as the Multilateral Instrument or MLI
Canada
8 May 2019
3
Canada Proposes Changes To Withholding Tax On Dividend Equivalent Payments
The Canadian federal budget (Budget 2019) tabled on March 19, 2019 (Budget Day) contains important tax changes relevant to participants in the stock lending market
Canada
30 Apr 2019
4
From Transfer Pricing To Tax Treaties: Canadian Cross-Border Tax Update
The two most significant Canadian cross-border tax developments in 2018 relate to transfer pricing and tax treaties.
Canada
27 Dec 2018
5
Canada Takes Next Step Toward Ratifying The MLI (To Implement Certain Tax Treaty Changes), And Removes Some Of Its Prior Reservations
The minimum standard to address treaty abuse consists of two parts: (i) an amended preamble, suggesting that covered tax treaties are intended to eliminate double taxation...
Canada
30 May 2018
6
Canada Begins Ratification Process For Multilateral Tax Convention To Implement BEPS
The OECD's Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting [PDF] was tabled in the House of Commons on January 31, 2018.
Canada
8 Feb 2018
7
New PPT Rule In The OECD's Multilateral Instrument To Displace Canadian GAAR?
On June 7, 2017, Canada signed the OECD's Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI)...
Canada
29 Nov 2017
8
An "America First" Tax Reform: Potential Impact On Canadian Companies
A nine-page framework (the Unified Framework for Fixing Our Broken Tax Code [PDF]) was released on Wednesday, September 27, by the "Big Six" group of Republican Congressional leaders...
Canada
9 Oct 2017
9
Canada Signs Multilateral Tax Agreement
Canada and 67 other jurisdictions signed the OECD's Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting on June 7, 2017, at a signing ceremony in Paris.
Canada
19 Jun 2017
10
Are Private Equity And Other Collective Investors Entitled To Tax Treaty Benefits?
In November 2015, Prime Minister Justin Trudeau and the other G20 leaders endorsed the OECD's base erosion and profit shifting (BEPS) measures.
Canada
17 Jan 2017
11
Significant Tax Treaty Changes Proposed In Multilateral Convention
On November 24, 2016, the OECD released a multilateral convention (the multilateral instrument or MLI together with a detailed Explanatory Statement.
Canada
29 Nov 2016
12
Financing Across Borders: The Impact Of The Final Section 385 Regulations
The recent finalization of Section 385 regulations by the IRS and Treasury Department marks a profound change in the manner that basic U.S./Canadian cross-border tax planning will be conducted.
Canada
16 Nov 2016
13
Budget Briefing 2016
The Honourable Bill Morneau, Minister of Finance, tabled the Liberal government's first budget on March 22, 2016 (Budget 2016).
Canada
31 Mar 2016
14
International Tax Reform 2015-BEPS Final Reports
On October 5, 2015, the OECD released its final reports relating to the OECD/G20 base erosion and profit shifting (BEPS) initiative.
Canada
7 Oct 2015
15
OECD Considers Availability Of Tax Treaty Benefits For Investment Funds, Pension Funds And Private Equity Funds
On November 21, 2014, as part of its Action Plan on Base Erosion and Profit Shifting (BEPS), the OECD released a discussion draft on "Follow-up work on BEPS Action 6: Preventing Treaty Abuse" (the Discussion Draft) for comments.
Canada
26 Nov 2014
16
IRS Simplifies Rules For Participants In Canadian Plans – Or Does It?
Under the US-Canada Income Tax Treaty, U.S. taxpayers who participate in Canadian registered retirement plans are not required to pay tax on the annual income and investment gains on their accounts.
Canada
24 Oct 2014
17
OECD Releases Discussion Draft On Tax Challenges Of The Digital Economy
In July 2013, the Organisation for Economic Co-operation and Development released its Action Plan on Base Erosion and Profit Shifting.
Canada
26 Mar 2014
18
OECD Releases Discussion Drafts On Hybrid Mismatch Arrangements
In July 2013, the Organisation for Economic Co-operation and Development released its Action Plan on Base Erosion and Profit Shifting.
Canada
21 Mar 2014
19
OECD Proposes Revisions To Tax Treaties To Prevent "Treaty Abuse"
The OECD released a discussion draft for public consultation, BEPS Action 6: Preventing the Granting of Treaty Benefits in Inappropriate Circumstances.
Canada
19 Mar 2014
20
Canada Signs FATCA Intergovernmental Agreement With The United States
Canada and the United States announced on February 5, 2014, that they had signed a long-awaited intergovernmental agreement (Canada–U.S. IGA) that dramatically expands the sharing of tax-related information between the countries.
Canada
7 Feb 2014
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