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.
Results 1 to 5 of 213
Most popular |Most recent


CRA updates views on taxable Canadian property look-through rule.

Canada - June 19 2017 A non-resident is taxable in Canada on gains realized on taxable Canadian property (TCP). TCP can potentially include shares of a corporation -...


Limited partnership at-risk rules do not apply to partnerships as members.

Canada - May 30 2017 A tiered-partnership structure is fairly common in Canada: i.e., where one partnership (a top-tier Partnership) is a member of another partnership (a...


Transfer-pricing audits and executive share awards.

Canada - May 15 2017 Within a multinational group, cross-border transfer-pricing fees often include an inter-company charge in respect of share-compensation awards made...


Canada Revenue Agency interprets construction PE article in OECD model tax treaty.

Canada, OECD - May 7 2017 Many of Canada's tax treaties follow Article 5(3) of the OECD's model tax treaty, which provides that a resident of the foreign treaty country...


CRA says no gain or loss is recognized on making a functional currency election.

Canada - May 7 2017 A corporation resident in Canada may elect to compute its income for Canadian tax purposes in a currency (the Functional Currency) other than the...