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International aggressive tax avoidance and tax evasion
- McCarthy Tétrault LLP
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- Canada
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- May 7 2013
Canada's 2013 federal budget (Budget 2013) released on March 21, 2013 introduces a number of measures to strengthen the ability of the Canada Revenue
Canadian "thin capitalization" rules: further broadening
- McCarthy Tétrault LLP
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- Canada
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- May 7 2013
Canada, like many developed countries, restricts the amount of interest a corporation resident in Canada (CRIC) may deduct on loans made by
Budget 2012 legislation more revisions to foreign affiliate "dumping" and shareholders loan rules
- McCarthy Tétrault LLP
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- Canada
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- November 16 2012
On October 15, 2012, the Minister of Finance (Canada) tabled a Notice of Ways and Means Motion (NWMM) in the House of Commons to implement certain measures from the March 29, 2012 Federal budget (Budget 2012) that were amended in draft legislation released on August 14, 2012 (August Proposals
Minister of Finance (Canada) releases revised budget proposals
- McCarthy Tétrault LLP
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- Canada
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- September 19 2012
The March 29, 2012 federal budget proposed amendments to a number of international tax measures contained in the Income Tax Act (Canada
Changes to rules for Canadian property dispositions by non-residents
- McCarthy Tétrault LLP
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- Canada
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- April 2 2012
Canada taxes non-residents on their gains from the disposition of taxable Canadian property (TCP
Bad news for aggressive taxpayers: Canada Revenue Agency wins another GAAR case
- McCarthy Tétrault LLP
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- Canada
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- January 10 2012
On December 16, 2011, the Supreme Court of Canada released its decision in Copthorne Holdings Ltd. unanimously dismissing the taxpayer’s appeal
CanadaBarbados tax treaty new protocol
- McCarthy Tétrault LLP
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- Barbados, Canada
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- January 10 2012
On November 8, 2011, a new protocol (Protocol) amending the Canada-Barbados Income Tax Agreement (Treaty) was signed by the two countries, updating the Treaty to conform with current tax treaties and to reflect Canada’s commitment to promote exchange of tax information in accordance with OECD standards
Payments to non-resident financial intermediaries update on Canadian withholding tax obligations
- McCarthy Tétrault LLP
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- Canada
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- January 10 2012
The Canada Revenue Agency has amended its administrative position on Canadian withholding tax obligations on payments of interest, dividends, royalties, etc., to non-residents to be effective on January 1, 2012 (now extended to January 1, 2013
Bad news for aggressive taxpayers Canada Revenue Agency wins another GAAR case
- McCarthy Tétrault LLP
- -
- Canada
- -
- December 19 2011
On December 16, 2011, the Supreme Court of Canada (SCC) released its decision in Copthorne Holdings Ltd. unanimously dismissing the taxpayer’s appeal
Foreign affiliate proposals some welcome and unwelcome changes
- McCarthy Tétrault LLP
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- Canada
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- September 12 2011
On August 19, 2011, the Department of Finance (Finance) released extensive proposed amendments (2011 Proposals) to the foreign affiliate rules which, in some cases, replace a number of the more controversial amendments that were contained in the proposed amendments released on February 27, 2004 (2004 Proposals) and that may be viewed as a significant shift in tax policy
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