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Tax Insights: 2016 New Brunswick budget – Tax highlights
On February 2, 2016, Finance Minister, Roger Melanson, delivered New Brunswick's 2016 budget.

Tax Insights: Trust loss restriction rules – Draft legislative proposals modify tax rules affecting funds and asset managers
On January 15, 2016, the Department of Finance released for consultation draft legislative proposals that would amend the “trust loss restriction rules.” The proposals address certain concerns raised by the asset management industry with the currently enacted rules.

Tax Insights: 2016 Annual tax filing and remittance deadlines for corporations
This Tax Insights outlines some of the more common corporate compliance requirements to be considered at this time of year.

Tax Insights: Draft legislative proposals modify tax rules for certain trusts and their beneficiaries
Draft legislative tax proposals released for consultation by the Department of Finance on January 15, 2016, modify the rules for estate donations and spousal and common-law partner (and similar) trusts.

Tax Insights: 2016 Federal budget – What could be in it
With Canada’s 2016 federal budget looming, we consider what tax measures our new government might have in store for us.

Tax Insights: New Non-Resident Employer Certification program – Payroll withholding relief for foreign employers with frequent business travellers to Canada
On January 12, 2016, the Canada Revenue Agency released its Non-Resident Employer Certification program for foreign employers with non-resident employees temporarily working in Canada.

Tax Insights: CBSA announces Phase 1 2016 audit priorities – What they mean for importers
The Canada Border Services Agency (CBSA) recently released its Phase 1, 2016 national trade verification (Audit) priorities.

Corporate tax rates and legislation: Q4 2015 Accounting status
This quarterly update discusses developments related to the accounting for income taxes in Canada.

Commodity Clips, 2015 Issue 4
This edition of Commodity Clips describes recent commodity tax developments.

Tax Insights: Estate tax update – Owning a US vacation home (2016 edition)
If you are a Canadian resident who owns US real estate, learn about your potential estate tax liability and how to reduce it.

Tax Insights: Estate tax update – Canadians living in the United States (2016 edition)
This Tax Insights explains how the United States determines US residency for estate and gift tax purposes.

Tax Insights: Estate tax update – Canadians transferred to the US (2016 edition)
US estate, gift and generation-skipping transfer tax exposure for Canadians transferred to the United States.

Tax Insights: Estate tax update – Owning US securities (2016 edition)
This Tax Insights discusses the application of estate tax to US securities and helps you to hold US securities in a tax-effective way, for example, by using a Canadian holding company.

Tax Insights: Estate tax update – US estate tax exposure for US citizens living in Canada (2016 edition)
The interaction of US and Canadian tax rules can have important implications for US citizens living in Canada.

Tax Insights: Estate tax update – US family members in the Canadian family-owned business (2016 edition)
Estate and will planning implications for US family members of Canadian family-owned businesses.

Tax Insights: Estate tax update – US estate tax exposure for Canadians (2016 edition)
This Tax Insights considers the exposure of Canadian residents to US estate tax.

2015 in Review: Canadian Tax and Other Key Highlights
What were the important changes and tax law updates that occurred in 2015? Our year-in-review timeline provides a detailed overview.

Tax Insights: Alert for private corporations – Some tax rates to increase
A Notice of Ways and Means Motion released by the Department of Finance on December 7, 2015, includes several tax changes that were not previously mentioned.

Tax Insights: Taxes for high earners to increase January 1, 2016 – Act now to save!
The Finance Minister confirmed that the top personal tax rate will increase on January 1, 2016. Find out what you might do to reduce the bite.

Canadian Insurance Taxation, 4th Edition
This latest edition of Canadian Insurance Taxation represents a comprehensive update written by PwC’s tax partners Jason Swales and Erdem Erinc.

Paying Taxes 2016: The Canadian Summary
Paying Taxes is a unique study from PwC, World Bank and IFC. Now in its tenth year, the study provides data on tax systems in 189 economies around the world, with an ability to monitor tax reform.

Tax Insights: Newfoundland and Labrador’s HST rate to remain 13%
Newfoundland and Labrador’s Premier-designate, Dwight Ball, has confirmed that the province’s HST rate will remain 13%. The former government had planned to increase the rate to 15% on January 1, 2016 (i.e. the provincial portion of the rate was to increase from 8% to 10%).

In Print: George Weston and the Characterization of Gains on Derivatives
The authors of this article argue that the Tax Court of Canada’s decision in George Weston Limited v. The Queen is a natural and expected result of 75 years of UK and Canadian jurisprudence on the treatment of foreign exchange gains and losses and gains and losses arising from hedging activity such as currency swaps and commodity futures trading.

Year-end tax planner – 2015: Helping individuals and owner-managed businesses save tax
The Year-end tax planner is designed primarily for individuals who have accumulated some wealth or own their own businesses (large or small). It includes year-end tax planning checklists.

Tax Insights: GST/HST and QST alert – 10 tax tips to consider at year end
With December 31, 2015 just around the corner, we share 10 GST/HST and QST tips that you should consider now.

Tax Insights: New tax rules for spousal, common-law, alter ego and joint partner trusts – Finance has heard our concerns
We are pleased to share with you a letter from the Department of Finance that comments on concerns relating to new tax rules for spousal, common-law, alter ego and joint partner trusts that apply starting January 1, 2016.

Tax Insights: Expected changes for taxing stock options – Be prepared
The federal Liberal party has pledged to cap the amount that employees can claim through stock option deductions, although “employees with up to $100,000 in annual stock option gains will be unaffected.” Details on how and when this change will be made are not yet known.

Tax Insights: Ontario’s Interactive Digital Media Tax Credit – What has changed
On November 2, 2015, Ontario released draft regulations that limit eligibility for the Ontario Interactive Digital Media Tax Credit (OIDMTC).

Tax Insights: New QST filing and reporting requirement for investment plan managers – Action required by November 20, 2015
Significant QST legislative amendments concerning investment plan managers received royal assent on October 21, 2015

Federal investment tax credits for R&D and property – 2015
Canada offers one of the most favourable packages of R&D tax incentives among the major industrialized countries. Federal, provincial and territorial R&D tax incentives are available.

Provincial and territorial R&D tax credits – 2015
Canada offers one of the most favourable packages of R&D tax incentives among the major industrialized countries. In addition to the federal incentives, taxpayers carrying on R&D can also benefit from provincial or territorial tax credits.

Tax Insights: 2015 Alberta NDP budget – Tax highlights
On October 27, 2015, Alberta’s President of Treasury Board and Minister of Finance, Joe Ceci, presented the NDP government’s first budget.

Tax Insights: Liberal party tax platform – What it could mean for you
Now that the results of Canada’s federal election are in, let’s look at Liberal party promises that can affect taxpayers and steps you can take to save tax.

Tax Insights – New tax rules for trusts apply January 1, 2016: It’s time to start planning
Changes to the tax treatment of trusts that apply starting January 1, 2016, have stimulated a lot of interest. A key change eliminates graduated tax rates for testamentary trusts and estates unless certain conditions are met.

Tax Insights: Travelling to the United States? Time to start counting your days
Every time you cross the border into the United States you could be getting closer to a US filing requirement.

Immigration Insights: Election 2015 – Federal parties’ immigration commitments
With the federal election on the horizon, we expect that each of the federal parties will be releasing additional details regarding their immigration platforms in the coming weeks.

The impact of BEPS on Global Mobility
A number of the BEPS actions will impact on how organizations manage and report on their globally mobile workforce.

In Print: 2014 saw significant work on BEPS, as well as some notable decisions
The 2014 year continued to bring significant changes to the global transfer pricing landscape, which in turn influenced the Canadian transfer pricing environment.

The big table: Film and video incentives in Canada 2015
Canada has numerous tax incentives for companies that develop film, video and digital content, including video games. For help understanding these incentives, navigate the interactive maps and read PwC’s big table publications.

Insurance industry – Key tax rates and updates (2015)
Tax changes, rates, deadlines and other useful information for the insurance industry in Canada.

Tax Insights: GST/HST and QST alert – Investment plans are required to obtain investor percentages – actions required by September 30, 2015
Distributed investment plans that are a selected listed financial institution are required to obtain information from investors to determine the plan’s provincial attribution percentage, so that the plan's GST/HST and QST liabilities can be calculated. Exchange-traded funds and exchange-traded series are excluded from this requirement.

Tax Insights: July 31, 2015 draft proposals – Alert for the mining industry
The Canadian mining industry will be affected by draft legislative proposals released by the Department of Finance on July 31, 2015.

Tax Insights: Canadian payroll relief clarified for foreign employers with frequent business travellers to Canada
On July 31, 2015, the Department of Finance released draft legislative proposals (July 31 proposals), which modify 2015 federal budget measures that provide foreign employers with non-resident employees temporarily working in Canada relief from payroll withholding requirements.

Tax Insights: CBSA announces Phase 2 2015 audit priorities – What they mean for importers
The Canada Border Services Agency recently released its Phase 2 (July) 2015 national trade verification (Audit) priorities. Phase 1 2015 audit priorities were released January 2015.

Corporate tax rates and legislation: Q2 2015 Accounting status
This quarterly update discusses developments related to the accounting for income taxes in Canada.

Tax Insights: July 1, 2015 – Ontario phases out recapture rate for recaptured input tax credits
This Tax Insights summarizes the changes to the recaptured input tax credit (RITC) reporting requirements.

Tax facts and figures: Canada 2015
Our Tax facts and figures: Canada 2015 convenient reference guide includes Canadian individual and corporate tax rates and deadlines, summaries of recent tax cases and a wide range of other valuable tax information.

Tax Insights: Alberta hikes personal and corporate taxes
As expected, Alberta’s NDP government has not proceeded with the level of personal tax increases, health levy and other tax initiatives proposed by its Conservative predecessors.

Tax Insights: TCC’s decision in Kruger – Valuation of option contracts
On May 26, 2015, the Tax Court of Canada (TCC) released its decision in Kruger Incorporated v. Her Majesty the Queen. The TCC considered whether Kruger was entitled, in computing its income for the 1998 taxation year, to deduct $91 million relating to a “mark-to-market” adjustment on unrealized foreign exchange option contracts.

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.

Tax Insights: US COOL – Hot topic for Canadian traders
The World Trade Organization’s (WTO) Appellate Body recently released its final report, upholding previous findings that the US Country of Origin Labelling (COOL) measures violate WTO trade rules and unfairly discriminate against beef and hog products imported into the United States.

10 Minutes on the OECD’s BEPS project
The OECD’s1 base erosion and profit shifting (BEPS) project will likely to spur the most significant changes to the taxation of international business since 1986.

The Top 10 considerations if you're being audited by the CRA
Are you are being audited by the Canada Revenue Agency? There are a number of key actions you can take to minimize the effort and time invested.

Global FS tax newsflash: Swiss Federal Supreme Court Rules in Withholding Tax Case for Danish Banks
The Swiss Federal Supreme Court has delivered two judgements regarding Swiss withholding tax refund cases for two Danish banks involved in derivative transactions over the dividend ex-date with Swiss equities.

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.

Tax Insights: Indirect tax deadlines – Ensure you comply
If you are responsible for your company’s indirect tax obligations, ensure you meet the deadlines discussed in this Tax Insights.

Tax Insights: 2015 Manitoba budget – Tax highlights
On April 30, 2015, Manitoba’s Finance Minister, Greg Dewar, delivered the province’s budget.

Tax Insights: 2015 Newfoundland and Labrador budget – High earners face tax hikes
On April 30, 2015, Nova Scotia’s Finance Minister, Ross Wiseman, delivered the province’s budget.

2015 Federal Budget - Impact on Immigration
Overall, with respect to immigration law, the Canadian government announced that it remains committed to reforming the Temporary Foreign Worker Program and ensuring that Canadians are first in line for available jobs.

Tax Insights: 2015 Ontario budget – Tax highlights
On April 23, 2015, Ontario’s Minister of Finance, Charles Sousa, presented the province’s budget.

2015 Federal budget: A pre-election budget
On April 21, 2015, the Federal Minister of Finance, Joe Oliver, presented the majority government’s budget. This Tax Insights discusses the tax initiatives proposed in the budget.

Tax Insights: 2015 Federal budget: Good news for foreign employers with frequent business travellers to Canada
Foreign employers with non-resident employees temporarily working in Canada will welcome a 2015 federal budget proposal that provides relief from payroll withholding requirements.

2015 Federal Budget - Instant Reactions
Our reactions and insights to the Federal Budget, tabled on April 21, 2015 by Federal Minister of Finance, Joe Oliver, are available here.

Tax Insights: 2015 Nova Scotia budget – Tax highlights
On April 9, 2015, Nova Scotia’s Finance and Treasury Board Minister, Diana Whalen, delivered the province’s budget.

Corporate Tax Rates and Legislation: Q1 2015 Accounting Status
This quarterly update discusses developments related to the accounting for income taxes in Canada.

Tax Insights: 2015 New Brunswick budget – High earners face big tax hikes
On March 31, 2015, Finance Minister, Roger Melanson, delivered New Brunswick's 2015 budget.

Tax Insights: 2015 Alberta Budget – Many Albertans to pay more
On March 26, 2015, Alberta’s President of Treasury Board and Minister of Finance, Robin Campbell, presented the province’s budget.

Tax Insights: 2015 Quebec budget
The Minister of Finance, Carlos Leitao, confirmed in his Budget Speech today that fiscal balance will be restored in 2015-2016. Here are the highlights of the 2014-2015 budget.

Tax Insights: 2015 Quebec budget – Tax highlights
The honourable Carlos Leitao, Quebec Minister of Finance, delivered today, March 26, 2015, the 2015 2016 Budget of the Government of Quebec. Below are the highlights of the most important tax measures included in the budget.

Commodity Clips, 2015 Issue 1
This edition of Commodity Clips describes recent commodity tax developments.

Tax Insights: 2015 Saskatchewan budget – Tax highlights
On March 18, 2015, Saskatchewan’s Minister of Finance, the Honourable Ken Krawetz, presented the province’s budget. The budget does not increase corporate or personal income tax rates, but does curtail certain tax incentives.

Tax Insights: Reporting requirements for Canadians holding stock options in foreign corporations – Ensure you comply
The CRA recently issued a technical interpretation that clarifies the reporting requirements for Canadian employees who hold awards to acquire shares in foreign corporations. Ensure you comply to avoid penalties.

Forging a winning culture
The first question an analyst is likely to ask a CEO is: ‘What is your strategy for the future?’ A better question would be: ‘Do you have the right culture to succeed?’

SR&ED Tax clip: Provincial and territorial R&D tax credits - 2014 (January 15, 2015)
Canada offers one of the most favourable packages of R&D tax incentives among the major industrialized countries. In addition to the federal incentives, taxpayers carrying on R&D can also benefit from provincial or territorial tax credits.

Tax Insights: Reporting obligations for labour organizations – Possible changes
Draft legislation – introduced as a Private Member’s Bill – would significantly expand the information that labour organizations (including labour trusts) must report to the Canada Revenue Agency.

Car expenses and benefits: A tax guide and employee log (2015)
Using a vehicle for business means you face an intricate set of tax laws when it comes to claiming your expenses. Find out how you can take advantage of certain tax deductions in this annual guide, summary and employee log.

Tax Insights: 2015 Annual tax filing and remittance deadlines for corporations
This Tax Insights outlines some of the more common corporate compliance requirements to be considered at this time of year.

Tax Insights: Consequences of a weak Canadian dollar: Transactions involving foreign affiliates
With the substantial depreciation of the Canadian dollar against its American counterpart, many taxpayers have accrued foreign exchange gains or losses on assets or liabilities denominated in US dollars.

Tax Insights: CBSA announces Phase 1 2015 audit priorities: What they mean for importers
The Canada Border Services Agency (CBSA) recently released its Phase 1, 2015 national trade verification (Audit) priorities. Phase 2, 2015 Audit priorities, will be released summer of 2015.

Tax Insights: QST tax alert for investment plan managers: Act now to fix reporting errors
Investment plan managers may need to act now to fix QST reporting errors. This affects investment plan managers that made tax transfer adjustment elections for GST/HST purposes with investment plans that allow the manager to effectively charge the plans a “blended rate” of GST/HST throughout the year.

Tax Insights: GST/HST alert: Reinsurance premiums paid to non-resident related parties — An update
The Department of Finance has clarified its “policy intent” for determining the amount of GST/HST that is payable by Canadian-resident insurers on reinsurance premiums paid to non-arm’s length non-resident insurers.

Tax Insights: Valuation adjustments after importation: Bad and good news for importers
The Canada Border Services Agency (CBSA) recently significantly changed its policy with respect to downward price adjustments and how they apply to declared value calculations for imported goods.

Tax Insights – GST/HST and QST alert: Structuring management fee rebates and distributions
The Tax Court of Canada’s recent decision in Invesco Canada Ltd. confirms that asset managers can structure fee arrangements with mutual fund trusts and institutional investors in a manner which only requires the asset manager to collect GST/HST (or QST) on the net management fee that is payable by the mutual fund trust to the manager.

Tax Insights: Canadian importers face higher customs duties – General Preferential Tariff (GPT) treatment ends for 72 countries
On January 1, 2015, the Canadian federal government withdrew the General Preferential Tariff (GPT) treatment benefits from 72 developing countries (including China) on imports into Canada. As a result, Canadian importers may now be paying more duty on certain imports.

Tax Insights – Estate tax update: Owning US securities (2015 edition)
This Tax Insights discusses the application of estate tax to US securities and helps you to hold US securities in a tax-effective way, for example, by using a Canadian holding company.

Tax Insights – Estate tax update: US family members in the Canadian family-owned business (2015 edition)
Estate and will planning implications for US family members of Canadian family-owned businesses.

Tax Insights – Estate tax update: Canadians transferred to the US (2015 edition)
US estate, gift and generation-skipping transfer tax exposure for Canadians transferred to the United States

Tax Insights – Estate tax update: Canadians living in the United States (2015 edition)
This Tax Insights explains how the United States determines US residency for estate and gift tax purposes.

Tax Insights: Estate tax update – US estate tax exposure for Canadians (2015 edition)
This Estate tax update considers the exposure of Canadian residents to US estate tax.

Tax Insights – Estate tax update: US estate tax exposure for US citizens living in Canada (2015 edition)
The interaction of US and Canadian tax rules can have important implications for US citizens living in Canada.

Tax Insights: Trading with Russia – Sanctions broadened for Canadian businesses in the oil exploration and production sector
On December 19, 2014, the Canadian government amended the Special Economic Measures (Russia) Regulations to broaden Canada’s trade sanctions against Russia.

Corporate Tax Rates and Legislation: Q4 2014 Accounting Status
This quarterly update discusses developments related to the accounting for income taxes in Canada.

Tax Insights: TCC rules in taxpayer’s favour in SR&ED case (Les Abeilles)
On October 23, 2014, the Tax Court of Canada (TCC) released its decision in Les Abeilles Service de Conditionnement Inc (in French only). The TCC overturned the Canada Revenue Agency’s position that the four projects under dispute were not scientific research and experimental development.

Commodity Clips, 2014 Issue 3
This edition of Commodity Clips describes recent commodity tax developments.

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.

2014 in Review: Canadian Tax Highlights
Our timeline provides an overview of the important changes and tax law updates that occurred in 2014.

Fall 2014 Economic and financial update – Quebec
Minister of Finance Carlos Leitão presented his Fall 2014 Economic and Financial Update and states that the government action will help restore sound public finances in Québec.

Wealth and tax matters
This edition includes eight articles relevant to private businesses, executives and Entrepreneurs.

Tax Insights: Outstanding legislative tax proposals announced before April 1, 2013 – Where do they stand?
As required by Canada’s Financial Administration Act, the Department of Finance recently provided Parliament a list of tax proposals that were announced before April 1, 2013, but have not yet been passed into law.

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.

Tax Insights: GST/HST and QST elections for nil consideration – Form will have to be filed!
The GST/HST and QST rules allow members of closely related groups to elect to treat certain taxable supplies made between the members as being made for nil consideration, if certain conditions are met. Generally, making this election gives the group a cash flow benefit.

Tax Insights: GST/HST and QST alert – Investors must issue notification of investor percentages – November 15, 2014 deadline
Distributed investment plans are required to obtain information from investors to determine the plan’s provincial attribution percentage, so that the plan's GST/HST liabilities can be calculated in accordance with the selected listed financial institution GST/HST reporting rules.

Tax Insights: Regulation 102 processes – What has changed?
Employers who send employees to work in Canada must comply with Canadian payroll regulations. This can involve various processes, such as applying for Canadian tax identification numbers and for tax withholding waivers, remitting taxes and issuing T4 slips.

Tax Insights: Income-splitting and other tax measures for families introduced
Today, the federal government introduced three income tax measures intended to relieve the tax burden for families.

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.

Tax Insights: British Columbia releases the Liquefied Natural Gas (LNG) Income Tax Act
Today, British Columbia introduced the much-awaited Liquefied Natural Gas Income Tax Act (the LNG Act) which provides important new details, including a reduction in the tax rates, an investment allowance for computing net operating income subject to tax, complex transfer pricing rules and deeming provisions.

Tax Insights: Trust loss restriction rules – Proposed amendments
On October 20, 2014, the Department of Finance released a Notice of Ways and Means Motion to implement tax relief measures that include proposed amendments to the “trust loss restriction rules.”

Tax Insights: Good news for US taxpayers with RRSPs or RRIFs
A recent US Internal Revenue Service announcement (Rev. Proc. 2014-55) makes it easier for Americans and Canadians who hold interests in registered retirement savings plans or registered retirement income funds to get favourable US tax treatment.

Tax Insights: The new Extractive Sector Transparency Measures Act: What it means for you
The Extractive Sector Transparency Measures Act requires public disclosure of government payments made by mining and oil & gas entities engaged in the commercial development of oil, gas and minerals.

Global FS tax newsflash: Update on application of VAT in international VAT groups
A recent European Court decision may have far reaching implications for international FS businesses operating VAT groups due to VAT charges now being created where previously there have been none between a head office location and its branch.

SR&ED Tax clip: Federal investment tax credits for R&D and property – 2014 (September 15, 2014)
Canada offers one of the most favourable packages of R&D tax incentives among the major industrialized countries. Federal, provincial and territorial R&D tax incentives are available.

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.

US Offshore Voluntary Disclosure podcast series - A five-part Tax Tracks podcast series
This podcast series sheds light on the question of whether an individual falls under the category of ‘US citizen’ and how to become compliant with the requisite US filings.

Tax Tracks Episode 73: “US Voluntary Disclosure" series – Complying with FATCA reporting: Forms W-8Ben and W-9
In this fifth episode of our 'US Offshore Voluntary Disclosure' series, Chris Chan discusses some FATCA reporting requirements. Looking at Forms W-8Ben and W-9, he discusses the distinctions between the two forms, why they need to be completed and the process and timelines involved.

Tax Tracks Episode 72: “US Voluntary Disclosure” series – Snowbirds and frequent visitors to the US: Are you a tax resident?
In this episode of our ‘US Offshore Voluntary Disclosure’ series, Ian Macdonald discusses the implications of spending extended periods of time in the US and the tax filing requirements that may result.

Tax Tracks Episode 71: “US Voluntary Disclosure” series – Understanding the US Offshore Voluntary Compliance Programs – Part 2
In this next episode of our ‘US Offshore Voluntary Disclosure’ series, Chantal Farrell-Carter continues to discuss the offshore voluntary compliance programs.

Tax Tracks Episode 70: "US Voluntary Disclosure" series – Understanding the US Offshore Voluntary Compliance Programs – Part 1
In the second episode of our ‘US Offshore Voluntary Disclosure’ series, Chantal Farrell-Carter looks at two of the options available under the offshore voluntary compliance programs.

Tax Tracks Episode 69: “US Voluntary Disclosure" series – Are you a US Citizen?
In the first episode of our ‘US Offshore Voluntary Compliance/Disclosure’ series, Ife Ashabo sets the stage by looking at the issue of US citizenship.

Tax Insights: New tax rules for testamentary trusts – The bad and the good (and some surprises)
Draft legislative proposals released by the Department of Finance on August 29, 2014, have important implications for estates and testamentary trusts, and for post mortem tax planning.

Tax Insights: Recommendations on countering treaty abuse – Where are we now?
This Tax Insights provides an overview of recent OECD/G20 and domestic initiatives that review and recommend approaches to counter treaty abuse, including “treaty shopping.”

Tax Insights: GST/HST reporting for the real estate sector: Are you compliant?
The Canada Revenue Agency is auditing the GST/HST reporting of taxpayers in the real estate sector.

Tax Insights: The snowbirds sing… and the IRS listens
For many Canadians, the opportunity to avoid a harsh winter by fleeing to the southern United States is irresistible. But some may have overlooked important tax implications.

Tax Insights: More changes to Form T1135, ‘Foreign Income Verification Statement’
The CRA has announced changes for taxpayers required to file Form T1135, ‘Foreign Income Verification Statement.’

Commodity Clips, 2014 Issue 2
This edition of Commodity clips describes recent commodity tax developments.

2014 Ontario budget: Higher taxes for higher earners and some corporations
On July 14, 2014, Ontario’s Minister of Finance, Charles Sousa, presented the majority government's budget. The July 14, 2014 budget reintroduces the tax measures proposed in the province’s May 1, 2014 budget.

Tax Insights: GST/HST pension plan compliance obligations
This Tax Insights discusses Goods and Services Tax/Harmonized Sales Tax compliance issues relevant to employers that have registered pension plans.

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.

Tax Insights: Structuring a partnership: CRA attacks GST/HST-exempt treatment of partnership distributions
Incorrectly structuring the activities of a partnership can cause GST/HST deeming rules to apply; resulting in a GST/HST liability for person’s involved in the partnership’s business.

Corporate Tax Rates and Legislation: Q2 2014 Accounting Status
This quarterly update discusses developments related to the accounting for income taxes.

Corporate Tax Rates and Legislation: Q3 2014 Accounting Status
This quarterly update discusses developments related to the accounting for income taxes.

Tax Insights: New IRS relief for US citizens living outside the US
On June 18, 2014, the US Internal Revenue Service announced changes to its offshore voluntary compliance programs that are expected to significantly increase the number of US persons that can participate in these programs.

Tax Tracks Episode 68: “Top global mobility issues facing Tax Directors” series — Tax equalization costs
In this final episode of our “Top global mobility issues facing Tax Directors” series, Candace Doig outlines the concept of tax equalization.

Tax Tracks Episode 67: “Top global mobility issues facing Tax Directors” series — Non-resident director fees
In this episode of our “Top global mobility issues facing Tax Directors” series, Nupur Rishi looks at the taxation of non-resident director’s fees.

Global FS tax newsflash: EU FTT – EU-10 come together with further statement of political intent
The spotlight returned to Brussels on May 6, 2014, as observers awaited an update on the latest developments on the EU Financial Transaction Tax at the ECOFIN meeting of finance ministers.

Tax Insights - June 2014 Quebec budget
The Minister of Finance Carlos Leitao, tabled a budget mainly aimed at economic recovery and restoring sound public finances.

Tax Insights: June 2014 Quebec budget – Tax highlights
Carlos Leitao, Quebec Minister of Finance, delivered today, June 4, 2014, the 2014/2015 Budget of the Government of Quebec.

May 2014 - Topical immigration issues affecting your global business
This audio recording of an HRS breakfast seminar provides an overview of corporate immigration requirements, with a focus on Canadian and US cross-border travel. It outlines key strategies and information to facilitate successful cross-border movement.

Tax Tracks Episode 66: “Top global mobility issues facing Tax Directors” series – Foreign pension plans
Our 'Top global mobility issues facing Tax Directors' series continues with Brandi Scales discussing foreign pension plans.

Tax Insights: GST/HST issues affecting the real estate and construction industries
This Tax Insights highlights Goods and Services Tax/Harmonized Sales Tax (GST/HST) issues relevant to the real estate and construction industries.

Top global mobility issues facing tax directors - A seven-part Tax Tracks podcast series
This podcast series is designed to provide Canadian corporate tax teams with a high-level understanding of issues impacting mobility programs to help them identify relevant corporate tax issues and areas of most risk.

Tax Insights: Alert for multinational companies: Payroll and immigration compliance
Cross-border employee travel into Canada raises various Canadian tax withholding and immigration compliance requirements. Multinational companies should consider whether they have the processes and controls in place to manage these requirements and the associated risks.

Tax Insights: Federal Court rules on 95(6)(b) in Lehigh
On April 23, 2014, the Federal Court of Appeal (FCA) released an important decision on the scope of paragraph 95(6)(b), an anti avoidance rule found in the part of the Income Tax Act that governs the tax treatment of ‘foreign affiliates’ of Canadian corporations.

Tax Tracks Episode 65: “Top global mobility issues facing Tax Directors” series — Deferred compensation arrangements
Our “Top global mobility issues facing Tax Directors” series continues with Kin Ngan discussing deferred compensation arrangements.

Corporate Tax Rates and Legislation: Q1 2014 Accounting Status
This quarterly update discusses developments related to the accounting for income taxes.

Commodity Clips, 2014 Issue 1
This edition of Commodity clips describes recent commodity tax developments.

Tax Insights: Tax Court of Canada finds corporate reorganization abuses section 84.1
In a judgment (Descarries) rendered on March 7, 2014, under the Informal Procedure, the Tax Court of Canada provided an example of a situation where, in the Court’s view, the object and spirit of section 84.1 had been abused, triggering the application of the general anti-avoidance rule (GAAR).

Tax Tracks Episode 64: “Top global mobility issues facing Tax Directors” series – Intercompany equity charge-back agreements
In this episode of our ‘Top global mobility issues facing Tax Directors’ series, Vasu Krithigaivasan discusses equity charge-back agreements that commonly exist between a Canadian subsidiary and its foreign parent company.

Being strategic in resources: JVs remain key - Global mining deals outlook / March 2014
Joint Ventures (JVs) have been an important part of the mining industry for decades and have been instrumental to the development of many major resource projects.

February 2014: Foreign reporting requirements in Canada and the US: What’s new and why you need to comply
Recently, tax jurisdictions have increased their reporting requirements for taxpayers holding offshore property and financial accounts. Combined with increased scrutiny, accurate reporting of these assets is becoming even more essential.

Tax Tracks Episode 63: “Top global mobility issues facing Tax Directors” series – Frequent business travellers
In the second episode of our “Top global mobility issues facing tax directors” series, Edmond Kwan discusses the importance of companies being aware of the travel patterns of their mobile employees.

Tax Insights: 2014 Manitoba budget: Tax highlights
On March 6, 2014, Manitoba’s Minister of Finance, Jennifer Howard, presented the province’s budget.

January 2014: International assignment basics: Planning for successful assignments abroad
This 60 minute webcast by PwC’s Human Resource Services practice explores the potential hazards for companies or individuals that are new to the realm of global mobility, or those looking to enhance their current processes.

Tax Insights: Foreign Income Verification Statement (Form T1135) – Transitional rules announced
Taxpayers required to file Form T1135, Foreign Income Verification Statement, must include additional information on foreign property, starting for taxation years ending after June 30, 2013.

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.

Tax Insights: 2014 federal budget: The demise of immigration trusts
Canada’s February 11, 2014 federal budget proposes to eliminate the tax benefits of immigration trusts. If you have relocated to Canada, this change could have adverse tax consequences.

Tax Insights: 2014 Quebec budget
Budget 2014-2015 confirms a return to fiscal balance in 2015-2016.

Tax Insights: 2014 Quebec budget – Tax highlights
Nicolas Marceau, Quebec Minister of Finance, delivered today, February 20, 2014, the 2014-2015 Budget of the Government of Quebec.

Tax Insights: Bare trusts, nominees and joint ventures: Temporary administrative leniency
A recent Canada Revenue Agency announcement grants taxpayers a temporary reprieve for a bare trust or nominee that reports the Goods and Services Tax/Harmonized Sales Tax on behalf of the members of a joint venture.

Tax Insights: 2014 British Columbia budget - Tax highlights
On February 18, 2014, British Columbia’s Minister of Finance, the Honourable Michael de Jong, presented the province’s budget.

Tax Insights: 2015 British Columbia budget – Tax highlights
On February 17, 2015, British Columbia’s Minister of Finance, the Honourable Michael de Jong, presented the province’s budget.

Tax Insights: British Columbia unveils its liquefied natural gas (LNG) tax
Today, British Columbia’s budget unveiled its much-anticipated liquefied natural gas (LNG) tax regime.

Tax Insights: 2014 Annual tax filing and remittance deadlines for corporations
This Tax Insights outlines some of the more common corporate compliance requirements to be considered at this time of year.

Tax Insights: 2014 Federal budget: How it affects you and the charitable and not-for-profit sector
This Tax Insights considers proposals in Canada’s February 11, 2014 federal budget that affect the charitable and not-for-profit 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.

2014 Federal budget: More tightening, few tax breaks
Read our analysis of the 2014 federal budget to learn about the tax implications for you.

Section 871(m) regulations webinar: Withholding on dividend equivalents
The new regulations under section 871(m) of the Internal Revenue Code, concerning the imposition of US federal withholding tax on certain equity-linked instruments, raises many issues for Canadian financial services companies.

Global IRW Newsbrief: Canada and the US sign FATCA Intergovernmental Agreement
The United States and Canada announced on February 5, 2014, that they have signed an Intergovernmental Agreement (IGA) to improve international tax compliance and to implement the US Foreign Account Tax Compliance Act (FATCA). The IGA must be ratified under Canadian laws before it comes into force.

Tax Insights: Trust loss restriction rules: Implications for funds and asset managers
Newly enacted trust loss restriction rules may have unintended and adverse tax implications for investment funds established as trusts.

Digging deeper into all-in cost disclosure - Mining's new frontier
Investors and analysts are increasingly calling for a more complete and transparent disclosure of total costs of production in the mining industry as margins have been squeezed by the recent decline in commodity prices.

Tax Insights: New regulations for passive foreign investment companies: What they mean for Canadian mutual fund owners
Temporary and final regulations recently issued by the Internal Revenue Service (IRS) and Treasury Department provide guidance for owners of passive foreign investment companies (PFICs).

Tax Tracks Episode 62: “Top global mobility issues facing Tax Directors” series – Cross border employment structures
This first episode in the ‘Top global mobility issues facing Tax Directors’ series discusses the need for Tax Directors to be engaged in the structuring an international work assignment.

December 2013: Temporary away from home rules: Comparing and contrasting Canadian regulations with other common expat locations
This 60 minute webcast by PwC's Human Resource Services practice compares and contrasts the tax treatment of these expenses or allowances between Canada and common expat locations.

Corporate Tax Rates and Legislation: Q4 2013 Accounting Status
This quarterly update discusses developments related to the accounting for income taxes.

Transforming the Tax Function
The tax function is often overlooked as an area for improvement. Shining a light on this area can reveal untapped opportunities where updates in technology, process, people, and/or data can lead to benefits for the broader business.

Commodity Clips, 2013 Issue 4
This edition of Commodity clips describes recent commodity tax developments.

Tax Insights: BEPS – Where are we?
This Tax Insights updates you on the status of BEPS and what to expect, and helps you deal with the changing environment.

September 2013: New UK legislation leads to a ‘perfect storm’ for employers
This audio recording of an HRS breakfast seminar provides an overview of significant legislative changes in the UK that impact payroll, residency, and reporting and remittance considerations for short-term, long-term and permanent assignments.

Operationalize your tax strategy: Tax Operations Manager
The tax function is often overlooked as an area for improvement. Shining a light on this area can reveal untapped opportunities where updates in technology, process, people, and/or data can lead to benefits for the broader business.

Tax Insights: Taxable benefit rate declining to 1%: Don’t act until January 1, 2014
The federal prescribed interest rate for taxable benefits will decrease to 1% on January 1, 2014. The rate – which is subject to change every quarter – is currently 2%. To lock in the 1% rate and save tax, you must not act until January 1, 2014.

Canadian mining taxation 2013
This publication provides guidance from the industry leaders on the complexities of mining taxation in Canada. Covers all project stages – from exploration to production – to help you manage your tax risks.

Tax Insights: Supreme Court of Canada rules in favour of taxpayers in Québec ‘rectification’ cases
Rectification cases are of interest to the tax community because the truth is, mistakes happen. Sometimes the only solution is to attempt to rectify the legal steps. At common law, rectification is an equitable remedy that may be available through the superior courts of the common law provinces.

Tax Insights: Alert for financial services industry: Measures of interest in Bill C-4 (2013 budget bill)
This Tax Insights looks at four anti-avoidance measures introduced in the 2013 federal budget of particular interest to the financial services industry. The proposed rules create fundamentally new tax concepts not previously seen in the Income Tax Act.

Tax Insights: Canada’s new non-resident trust rules: What they mean for global equity plans
Newly enacted non-resident trust (NRT) rules will likely create tax liabilities and filing requirements for global equity plans that use foreign trusts and have Canadian-resident participant employees.

Innovation surge sparks oil sands opportunities
Innovation is creating opportunities in Canada's oil sands industry. Oil sands executives and associations share their views in our report. A Chinese version of this report is also available.

创新浪潮 - 点燃油砂业机遇 (Technology in the Oil Sands - Chinese Version)
加拿大的油砂为世界提供了长期、稳定的 能源来源,也将成为供应世界日趋增长的 石油产品需求的重要来源,尤其是在亚洲 经济迅速发展的情况下。我们的报告旨在说明能 使之实现的非常规途径。

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.

Tax Insights: Improved processing for Regulation 102 and 105 waiver applications
A recent change announced by the CRA means that some non-residents who perform services in more than one location in Canada may send their Regulation 102 or Regulation 105 waiver applications to a Tax Services Office that has been designated as an International Waivers Centre of Expertise.

Tax Insights: SR&ED Form T661 revised: Claim preparer information required
On October 31, 2013, the Canada Revenue Agency released revised Form T661, Scientific Research and Experimental Development Expenditures Claim, which contains new Part 9 – Claim preparer information. The revised form is required for claims filed starting January 1, 2014.

Tax Insights: Ontario increases personal taxes on some dividends and studies corporate tax incentives
According to Ontario’s fall economic statement, presented today by Finance Minister Charles Sousa, the government will study an incentive that rewards research and development (R&D) incremental spending and “pay or play” tax incentives.

Tax Insights: New US Medical Device Excise Tax: What it means for your company
Since January 1, 2013, manufacturers, producers and importers of medical devices have been liable for a 2.3% US federal excise tax, known as the Medical Device Excise Tax (MDET), on sales made in the US.

Tax Insights: QST: Simplified method eliminated – What this means for large businesses
Starting January 1, 2014, large businesses can no longer use the simplified method (5%) to calculate input tax refunds (ITRs) in respect of expense reimbursements and allowances paid to employees.

Tax insights: Introduction of a refundable tax credit for the integration of Information Technologies in manufacturing SMEs (No. 2013-14)
The objective of this new program from the Quebec Government is to support Quebec manufacturing companies that want to invest in technology and integrate IT in their business processes by offering a refundable tax credit pertaining to expenditures on qualified management software package.

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.

Corporate Tax Rates and Legislation: Q3 2013 Accounting Status
This quarterly update discusses developments related to the accounting for income taxes.

Tax Insights: The Transalta case: Can stock plans be deductible in Canada?
In Transalta Corporation v. The Queen, the Tax Court of Canada (TCC) found that shares issued under a performance share unit plan were a deductible corporate expense.

Commodity Clips, 2013 Issue 3
This edition of Commodity clips describes recent commodity tax developments.

Global FS tax newsflash: From CRD IV to country-by-country tax reporting for all large companies and groups?
CRD IV: For banks and in place for 2014 - capital management, bonus caps, corporate governance and transparency, including country-by-country tax reporting. There is much about CRD IV that is critical for banks to understand and for financial services to take note of. This Newsflash looks at the country-by-country reporting (and auditing) aspects.

Global FS tax newsflash: OECD’s BEPS paper released. Not aimed at financial services… but clear implications…
The OECD's BEPS project is not primarily directed at the FS sector. However, there are various measures and work streams proposed that cause issues that are of very considerable interest - and application - to FS businesses.

Global IRW Newsbrief: Implementation of the International Tax Compliance (United States of America) Regulations 2013 – Guidance Notes
On August 14, 2013, HM Treasury and HMRC issued updated Guidance Notes in respect of the Implementation of The International Tax Compliance (United States of America) Regulations 2013 laid before the UK House of Commons earlier this month. This version of the guidance supersedes any versions previously published.

Tax Insights: Non-resident trust rules enacted: Transitional measures to consider
Newly enacted rules for non-resident trusts include relief for NRTs that have property contributed by non-Canadian residents. If an NRT is eligible for this relief, an election must be made to obtain the benefit. Other transitional rules may also be available to an NRT.

Tax Insights: Taxable benefit rate rising to 2%: Act before October 1, 2013
The federal prescribed interest rate for taxable benefits will increase to 2% on October 1, 2013. The rate – which is subject to change every quarter – has been 1% since April 1, 2009. To lock in the 1% rate and save tax, you must act before October 1, 2013.

Global IRW Newsbrief: The International Tax Compliance (United States of America) Regulations 2013 effective on September 1, 2013
On August 7, 2013, HM Treasury and HMRC laid the International Tax Compliance (United States of America) Regulations 2013 (UK Regulations) before the UK House of Commons. This Newsbrief identifies key changes and certain additions from the proposed UK Regulations which were released in May 2013.

Tax Insights: Preventing treaty shopping: Finance seeks input on possible measures – Issue 2013-09
The Department of Finance has released a consultation paper on possible measures to prevent ‘treaty shopping.’ Comments must be submitted to Finance by December 13, 2013.

Tax Insights: Recent CRA practices deny Regulation 102 waiver requests
Recent Canada Revenue Agency (CRA) practices have made it difficult for some non-resident employees working in Canada to obtain CRA waiver approval.

Tax Insights: More details needed on Foreign Income Verification Statement (Form T1135): Ensure you comply
Taxpayers required to file Form T1135, 'Foreign Income Verification Statement,' must include additional information on foreign property, starting taxation years ending after June 30, 2013.

Tax Insights: Extension of and improvement to the TCEB until 2025
Extension of the refundable tax credit for the development of e-business (TCEB) to 2025, raising of the tax credit cap for eligible employees to the amount of $22,500, and clarifications regarding the activities that qualify for the purpose of issuing certificates for employees.

Tax Insights: Bill C-48 gets royal assent — Implications for Canadian companies with foreign affiliates
This Tax Insights focuses on foreign affiliate measures in Bill C-48, Technical Tax Amendments Act, 2012, which received royal assent on June 26, 2013. It highlights some important dates.

Tax Tracks Episode 61: Soft-Moc Federal Court of Canada decision
In this episode we discuss the Soft-Moc case: what led to the dispute, the Federal Court of Canada's decision, and what you can do to help prevent this from happening to your organization.

Tax Tracks Episode 60: Will your foreign-based transfer pricing documentation withstand CRA scrutiny?
In this episode of Tax Tracks, we examine what could happen when a Canadian company’s foreign parent prepares its transfer pricing documentation. To ensure this documentation withstands CRA scrutiny, it should be reviewed to ensure that it meets Canadian standards.

May 2013: Foreign pension plans: Impact on Canadian companies and their employees
This webcast examines the implication to your company and its employees of participating in foreign pension plans.

PKN Alert: OECD base erosion and profit shifting project – update on transfer pricing issues
This PKN Alert provides the highlights and our initial comments on the proceedings.

Global IRW Newsbrief: US government announces six-month extension to FATCA effective dates
The IRS and the US Department of the Treasury issued Notice 2013-43 announcing revised timelines for implementing various provisions under FATCA.

Tax Insights: July 12, 2013 draft legislative proposals: Important implications for foreign affiliates
Canadian corporations with foreign affiliates may be affected by draft legislative proposals released by the Department of Finance on July 12, 2013.

Investing in Canada: Providing expertise to assist foreign investors with the requirements of the Investment Canada Act (ICA) – Canadian Net Benefit Test
The Investment Canada Act (ICA) outlines provisions for reviewing foreign investments in the Canadian mining sector, as well as framework criteria for assessing whether such investment is likely to be of “net benefit” to Canada.

Corporate Tax Rates and Legislation: Q2 2013 Accounting Status
This quarterly update discusses developments related to the accounting for income taxes.

Global FS Tax Newsflash: EU FTT – Will the Commission’s proposal survive?
This Global FS Tax Newsflash provides an update on what continues to be a highly political topic.

Global FS Tax Newsflash: The Italian FTT – deferral of key dates
It was announced in Italy that key dates for payment of the tax and the start of the derivatives regime would be deferred.

Tax Insights: British Columbia budget — June 2013 (Issue 2013-04)
On Thursday, June 27, 2013, British Columbia’s Minister of Finance, the Honourable Michael de Jong, introduced the province’s post-election budget.

Global IRW Newsbrief: Draft FATCA-related IRS forms: A snapshot of those released so far
Preparation for compliance with FATCA is well underway and a key element will be the various forms used to communicate between withholding agents, their payees, and the Internal Revenue Service (IRS).

Global IRW Newsbrief: European Commission seeks to expand automatic information exchange between EU Member States
European Union Tax Commissioner Algirdas Šemeta on June 13, 2013 presented a Proposal for a Council Directive intended to combat tax evasion by expanding the scope of the automatic exchange of information between EU Member States.

Tax Tracks Episode 59: “What if" series — Significant tax implications to Canadian residents working for a US employer in Canada
In this episode of Tax Tracks, PwC’s Linda Lee discusses the payroll obligations for US employers with Canadian employees working in Canada and the repercussions for the Canadian employees.

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

Global IRW Newsbrief: HM Treasury and HMRC release details outlining the implementation of FATCA in the UK
This Newsbrief identifies key changes from the draft UK Regulations released in December and highlights relevant aspects of the associated Guidance Notes.

Commodity Clips, 2013 Issue 2
This edition of Commodity clips describes recent commodity tax developments.

Global IRW Newsbrief: BMF announces the release of the German Intergovernmental Agreement for implementing FATCA
This Newsbrief provides an overview of the key elements of the German-U.S. IGA and how it compares to the Model 1 IGA.

Global FS tax newsflash: UK’s challenge blocked for now but UK Treasury indicates they will not let it be
In April 2013, the UK launched a legal challenge against the introduction of an EU Financial Transaction Tax under the Enhanced Cooperation Procedure. On May 31, 2014, the Court of Justice of the European Union released its decision on the UK’s challenge.

Tax Tracks Episode 58: “What if" series – Significant tax implications to Canadian residents working for a US employer in the US
In this episode of Tax Tracks PwC’s Vasu Krithigaivasan discusses the payroll considerations and payment of travel expenses for Canadian residents working in the US for a US employer.

Tax Insights: Supreme Court of Canada ruling in Daishowa-Marubeni — Tax treatment of reforestation obligations on sale of forestry assets
The Supreme Court of Canada ruled in favour of the taxpayer in Daishowa-Marubeni International Ltd. v. The Queen (DMI).

Tax Tracks Episode 57: “What if” series – Payroll issues for cross-border employees receiving incentive compensation
In this episode of Tax Tracks, David de Souza discusses payroll issues for cross-border employees related to incentive compensation.

Tax Insights: Does your documentation reflect the five questions?
To support a scientific research and experimental (SR&ED) claim, contemporaneous documentation should reflect the current 5-question assessment approach – a refinement of the three-criterion approach.

Tax Insights: Changes to Quebec's mining tax regime
After several months of deliberation and uncertainty, the Quebec government has finally announced changes to its mining tax regime.

Tax memo: US federal payroll tax requirements: Action must be taken by June 30, 2013 (Memo No. 2013-16)
Outlines a US program that gives employers a way to reduce US federal payroll tax penalties if they act before June 30, 2013.

Global IRW Newsbrief: The widespread reach of FATCA: How will it affect your business?
Understanding the impact of FATCA and the path forward for non-financial multinational businesses.

Tax Tracks Episode 56: “What If” series – Payroll issues with respect to expatriate’s stock option grants
In this episode of Tax Tracks, Carola Trolley explores payroll issues with respect to expatriate’s stock option grants.

Global BCM tax newsflash: Federal Administrative Court decision on beneficial ownership in equity finance transactions
This Newsalert draws your attention to the third Federal Administrative Court decision related to the definition of beneficial ownership from a Swiss withholding tax perspective in the case of derivative transactions.

Global IRW Newsbrief: New FATCA guidance for qualified intermediary, withholding foreign partnership, and withholding foreign trust applicants
The Internal Revenue Service (IRS) released important guidance on its website for entities that are classified as foreign financial institutions (FFI) under the provisions of the Foreign Account Tax Compliance Act (FATCA) and considering applying for qualified intermediary (QI), withholding foreign partnership (WP), or withholding foreign trust (WT) status.

Global FS tax newsflash: Legal challenge to the EU FTT – what happens now?
Recently, the UK launched a legal challenge against the EU Financial Transaction Tax (FTT). The UK has received support for its challenge from Luxembourg.

Tax Tracks Episode 55: Transfer Pricing Memo 14 - The CRA endorses OECD revisions
In this episode of Tax Tracks, Joanne Hawley discusses the November 2012 Transfer Pricing Memo – TPM 14

2013 Ontario Budget
On May 2, 2013, Ontario’s Minister of Finance, Charles Sousa, presented the province’s 2013 budget. The budget does not change corporate or personal income tax rates.

Global IRW Newsbrief: IRS releases draft FATCA registration forms and additional information regarding FFI lists
The Internal Revenue Service (IRS) released draft Form 8957, Foreign Account Tax Compliance Act (FATCA) Registration, for public review and comment on April 5, 2013.

Global IRW Newsbrief: New multilateral action to combat tax evasion
On April 9, the Government of the United Kingdom announced an agreement with France, Germany, Italy and Spain to develop and pilot multilateral tax information exchange arrangements.

Tax memo: 2013 Manitoba budget (Memo No. 2013-14)
On Tuesday, April 16, 2013, Manitoba’s Minister of Finance, Stan Struthers, presented the province’s 2013 budget, raising provincial sales taxes from 7 to 8 per cent.

Global FS tax newsflash: Italian FTT – Latest developments
This Global FS tax newsflash provides an update on the latest Italian FTT developments.

Tax memo: 2013 Federal budget – Alert for mining companies (Memo No. 2013-13)
This Tax memo outlines unexpected proposals in the 2013 federal budget that affect Canada’s mining industry.

Global IRW Newsbrief: Applying FATCA to captive insurance arrangements: Surprising results may occur
A captive insurance company is an example of an entity that can produce surprising results when the FATCA rules are applied - affecting both the captive and other entities involved in the arrangement.

March 21, 2013 Federal Budget: How it affects you and the charitable and not-for-profit sector
Brenda Lee-Kennedy and Audrey Diamant share highlights from the federal budget related to charities, other not-for-profit entities and charitable giving.

The Insurance Industry and FATCA – Moving from assessment to implementation: Top 13 in ‘13
Highlights 13 key areas to concentrate on through the remainder of 2013 as you move your FATCA Program from impact assessment into implementation.