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: Toward a new system for the taxation of corporate groups in Canada: Has the time (finally) come? This paper examines the debate over introducing more formal systems of group reporting in Canada.
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: Rewarding innovation: Improving federal tax support for business R&D in Canada Business innovation is key to a creating a highly productive Canadian economy. This paper looks at the impact of the federal R&D tax credit, and proposes tax options aimed at improving Canada’s innovation performance. It argues that Canada’s best bet is to focus on creating a competitive tax system across the entire innovation value chain.
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: Telltale times: US taxpayers and their offshore assets Are you a U.S. citizen living in Canada (or elsewhere outside the U.S.) holding financial assets that are not in the U.S.? The new FATCA rules could affect you.
In Print: Personal Tax Planning in the New Year Get tips in this article from PwC's Bruce Harris and Kathy Munro to help with your tax planning this year.
In Print: A New, Lower, Low This article focuses on one of many services affected by the federal government’s decision to amend the Excise Tax Act: discretionary investment management.
In Print: The Dilemma of GlaxoSmithKline: Unreasonable in the Circumstances? This paper examines how the TCC reached its decision in the GlaxoSmithKline Inc. vs the Queen case.
In Print: Indirect Tax and Customs Issues of (Re)structuring a Supply Chain PwC’s Eric Paton analyzes the customs and indirect tax implications on an organization’s supply chain. Read his paper to learn the negative impact and options businesses should consider.
In Print: Property Leasing into Canada: How to Open a Closed Market This article reviews the basic income tax concepts relating to cross-border leases of tangible personal property and the Canadian rules that apply to non-resident lessors.
In Print: International Financial Reporting Standards: Tax and Reporting Implications of the New Canadian GAAP This PwC In Print article examines the tax implications of transitioning from Canadian GAAP to IFRS.
In Print: The Foreign Affiliate Fresh Start Rules This PwC In Print article discusses the policy behind the foreign affiliate fresh start rules and proposed amendments to the rules.
In Print: Enhancing Canada’s International Tax Advantage This In Print issue features a speech by PwC’s Canadian National Tax Services leader Nick Pantaleo at the Canadian Tax Foundation’s May 2009 Prairie Provinces Tax Conference.
In Print: Ontario PST Harmonization This article discusses the characteristics of the proposed Ontario Value-Added Tax (VAT).
In Print: Ontario to Harmonize their Sales Tax with the GST Learn how Ontario's harmonized tax system will impact the information technology (IT) sector.
In Print: A Confluence of Uncertainties: The GST and Financial Services This PwC publication explains the difficulties in determining what intermediary financial services are GST-exempt as opposed to taxable.
In Print: Goods and Services Tax Reaches a Difficult Age This PwC In Print issue identifies the GST's successes and failures.
In Print: HST and Retail Issues This PwC 1997 CICA Symposium paper details why tax inclusive pricing remains a risk for "PST provinces" such as Ontario, that will proceed with melding sales taxes with the GST.
In Print: Navigating the New Bilateral Limitation-on-Benefits Rule This PwC In Print issue discusses the new limitation-on-benefits article and how the significant policy change may impact Canadian taxpayers.
In Print: New Section 261: The Tax Calculating Currency Rules This PwC article shares how the new calculating currency rules in section 261 of the Income Tax Act may benefit taxpayers
In Print: Dutch Co-ops: A Primer International tax practitioners are reinventing Netherlands-based Dutch cooperatives as a holding company and a financing or licensing vehicle. Learn more about co-ops including tax and non-tax considerations in this publication.
In Print: Taxation Year of a Foreign Affiliate The “taxation year of a foreign affiliate” is central to a foreign affiliate regime but the Income Tax Act doesn’t clearly define it. PwC’s Eric Lockwood shares research on the matter.
In Print: The Functional Currency Election and Foreign Affiliates The Income Tax Act’s subsection 261(6.1) adds another layer of complexity and compliance to the foreign affiliate regime. This article shares anomalies businesses may encounter when applies the new rules.
In Print: Canadian Export Controls This PwC Canada paper provides an overview of Canada’s export controls program.
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.
In Print: Good News for Barbados Qualifying Insurance Companies A technical interpretation from the CRA has put an end to the uncertainty surrounding the Canadian tax treatment of distributions from Barbados QICs to their Canadian parent companies.
In Print: Mexico’s Corporate Flat Tax Regime This article provides a basic overview of the new tax regime and aims to help Canadian companies operating in Mexico understand how this new regime may affect their current and future tax and cash positions in the country.
In Print: Planning opportunities for public sector bodies PwC's James Capobianco examines opportunities for the public sector to maximize their GST/HST recoveries.
In Print: Tax Incentives to Go Green This article highlights ways to benefit from the green agenda that federal and provincial governments are pushing in the form of new taxes and fees.
In Print: Canada's Tax Regime: Complexity Undermines Competitiveness – PwC's Total Tax Contribution Survey This article discusses the results of a recent survey by PricewaterhouseCoopers examining the tax contributions of large Canadian corporations.
In Print: Provincial Environmental Fees Provincial environmental fees get much less attention than sales taxes, but present significant administrative costs and challenges for many businesses.
In Print: Provincial Move to Carbon Tax This article provides a brief status report on the move to carbon taxes by Canadian provinces.
In Print: The Anti-Tax Haven Initiative and the Foreign Affiliate Rules The March 19, 2007 Canadian federal budget proposed to deny deductions for interest on funds used by Canadian taxpayers to invest in foreign affiliates.
In Print: Drop Shipment Rules This article provides background on the GST Drop Shipment rules, and discusses CRA’s evolving interpretation as to the types of scenarios that may not fall within the drop shipment provisions, as well as those that may create a requirement for non-residents to register for the GST.
In Print: Ontario PST and Software This article discusses the application of Ontario Retail Sales Tax to software and software-related services, comments on the increasing complexity of the rules, and highlights areas where the interpretation of the Ministry is at odds with that of the industry as a whole.
In Print: Foreign Affiliate Update This article provides an update on a number of key foreign affiliate technical amendments to the Income Tax Act that the Department of Finance has released.
In Print: British Columbia's Tax Refund Regime: International Financial Activities By providing a refund of provincial income tax paid in respect of qualifying activities carried out in British Columbia, the province’s international financial activity regime enables corporations to shift pre-tax income from higher rate jurisdictions to its more moderate system.