We use cookies to customise content for your subscription and for analytics.
If you continue to browse Lexology, we will assume that you are happy to receive all our cookies. For further information please read our Cookie Policy.
Lexology logo
  Request new password

James A. Fraser Miller Thomson LLP

Results 1 to 5 of 7



Overview of new Canada-Hong Kong Tax Treaty *

Canada, Hong Kong - April 17 2013
On November 11, 2012, the Government of Canada signed a Tax Treaty with the Government of the Hong Kong Special Administrative Region of the People's…

Co-authors: Lyne M. Gaulin.


Cross-border employee transfers: planning and compliance are critical *

Canada - June 13 2012
Transferring employees between members of a corporate group can be an effective way to leverage expertise, promote existing corporate culture, transition business units and develop new markets. 


Change to Canada-US Tax Treaty affecting cross-border employees *

Canada, USA - December 19 2011
Article XV(2) of the Canada-US Tax Treaty (the “Tax Treaty”) provides for an exemption from taxation of remuneration derived by an employee resident in a country (referred to herein as “residence state”) in respect of temporary employment exercised in the other country (referred to herein as the “source state”).


Applications for exemption under the Canada-United States Income Tax Convention *

Canada, USA - August 31 2011
Charities and non-profit organizations in Canada and the U.S. Tax Convention (the “Treaty”) and whether it may be possible to obtain an exemption from taxes that would otherwise apply to such income.


International tax: recent changes to “taxable Canadian property” regime for purchasers and non-resident vendors of TCP *

Canada - July 21 2010
Changes introduced by the 2010 Federal Budget will impact the obligations imposed on non-resident vendors of "taxable Canadian property" ("TCP"), such as real property situated in Canada and shares of Canadian private and public corporations, and purchasers of such properties under the Income Tax Act (Canada) (the "Act").


Next »