In Print: Foreign Affiliate Reorganizations — Where Are We Now? This article provides an overview of the "final" FA reorganization rules and includes a discussion of the practical planning considerations that arise when working with these provisions.
In Print: FA Dumping – PUC Offset This article outlines two significant changes, both retroactive, to the paid-up capital (PUC) offset rules. The first relates to withholding tax obligations if a PUC offset notification is not filed in time. The second would require the PUC reduction for each cross-border class to be proportionate to that class’s PUC in certain situations.
In Print: Corporate Tax – the Bigger Picture Do large Canadian corporations pay their fair share of taxes? This short article highlights the issues and the findings of a survey of 63 top Canadian companies.
In Print: Aggressive International Tax Planning by Multinational Corporations – The Canadian Context and Possible Responses Aggressive tax planning has become a hot political issue. Tax inversions by familiar US corporations are in the news. From the perspective of the Canadian tax system, this paper considers aggressive tax planning, highlighting the OECD’s efforts to combat base erosion and profit shifting.
In Print: Unguarded border, well-guarded wealth US revocable trusts present special challenges when high-net-worth individuals move to Canada because of distinct tax rules on opposite sides of the border.
In Print: Managing a global tax department Adding strategic value to the organization is now part of the global tax leader’s role. The challenge is to overcome inefficient manual processes through well-chosen strategic investments in people, processes, technology and data.
In Print: BEPS and Indirect Tax BEPS is likely to have important implications on indirect tax in the digital economy. The OECD is studying the topic, and Canada’s Department of Finance has sought input from stakeholders.
In Print: Financial Sector Spending Surge – New Project Needs The federal government is pondering some welcome GST changes that can help those who provide outsourcing services to the financial sector.
In Print: Canadian taxpayers are facing aggressive audits by CRA Canadian taxpayers face a changing transfer pricing environment, emphasized by BEPS mandate of the OECD, while continuing to manage aggressive CRA audits in respect of transfer pricing issues, and procedural and timing aspects of the audits themselves. This article reviews these issues and related transfer pricing developments in 2013.
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: Are you ready for the upstream loan 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).
In Print: GST and Pension Funds - The Hole Story This award-winning In Print issue discusses the impact of the GST on pension funds for organizations in the private and public sector.