In print: It’s 11 pm. Do you know how much GST cost your portfolio is bearing? This In print sheds light on the rising GST cost of investing.
In Print: The Anti-Tax Haven Initiative and the Foreign Affiliate Rules In addition to an overview of the new upstream loan provisions, this article by Ken Buttenham, a partner in our Toronto office, provides a framework for determining when they will apply, highlights inherent uncertainties in the legislation and offers suggestions for dealing with the new rules.
In print: Regulation 105 and Regulation 102 Tax Withholdings: Challenges and Potential Improvements This In print addresses challenges created by the current withholding regime in the Income Tax Act and regulations 105 and 102, from the joint perspectives of a tax advisor and a taxpayer
In print: The foreign affiliate dumping proposals – A perspective from a member of the Advisory Panel on Canada’s system of international taxation In this article, the author, a member of that Panel, provides background to the Panel’s recommendation behind the proposals and views on the appropriateness of the proposals.
In print: Beneficial ownership as a treaty anti-avoidance tool? In this article, the authors first canvass the history of the beneficial ownership concept in tax treaties and then discuss the recent CRA and OECD attempts to broaden the rule.
In Print: Foreign Affiliate Dumping The March 2012 federal budget introduced a new rule that significantly restricts a Canadian subsidiary owned by a foreign corporation from investing in a foreign affiliate.
In print: Planning for International Business Transactions, 1991-2011 In this article, the author reviews major legislative, economic and societal trends that have affected cross-border tax planning over the past twenty years.
In print: Foreign affiliates: Tracing the purpose and use of funds This article describes the tracing requirements for certain foreign affiliate provisions, and demonstrates how interest-tracing concepts can be applied to support the purpose and use of funds by a foreign affiliate.
In Print: Trading or dealing in indebtedness offshore: Paragraph 95(2)(1) revisited PwC’s Jayme Yeung offers insight on the interpretive issues and the practical application of the rules in the Income Tax Act’s paragraph 95(2)(l).