In Print: Recommended Amendments to the Upstream Loan Rules The upstream loan rules announced on August 19, 2011 and enacted on June 26, 2013 require an analysis of all loans or indebtedness owing to foreign affiliates of a Canadian taxpayer
In Print: Treaty Shopping and Base Erosion and Profit Shifting Action 6 This article discusses the treaty shopping proposals in the September 2014 Organisation for Economic Co-operation and Development (OECD) report and Canada’s 2014 federal budget, commenting on the direction that Canada may take to counter treaty shopping.
In Print: Blindly following the tax advice of the Canada Revenue Agency (CRA) can lead to problems! The Academy of Applied Pharmaceutical Sciences recently learned the hard way that advice provided by a CRA auditor may not necessarily apply to future reporting periods.
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: 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