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Overview of limitation on benefits article in Canada-U.S. Tax Treaty

Miller Thomson LLP
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Canada, USA
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April 17 2013

The Canada-United States Tax Treaty (the "Tax Treaty") is unique among Canada's tax treaties in its approach to prevent "treaty shopping". Treaty

CRA confirms tax treatment of US downstream absorptive merger

Thorsteinssons LLP
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Canada, USA
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April 2 2013

In 2012-0449371I7, the Canada Revenue Agency (CRA) confirmed that a both an upstream and a downstream absorptive merger under US corporate law would

Recent developments for the fourth quarter 2012

Baker & McKenzie
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Austria, Belgium, Canada, China, Ireland, Luxembourg, Malaysia, Morocco, Philippines, Singapore, South Korea, Spain, United Kingdom, USA
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March 18 2013

The North American Global Equity Services ("GES") practice group is pleased to provide the current edition of our Clients and Friends Newsletter

The (far) reach of US tax evasion laws

Thorsteinssons LLP
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Canada, USA
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March 9 2013

A recent newspaper article described a criminal prosecution commenced by the United States against a Swiss Bank. The charge alleged that the bank

Goin' South: planning to avoid unexpected southern exposure

Davis LLP
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Canada, USA
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February 27 2013

Two common concerns for Canadians who are thinking of regularly spending time in the United States are will they become subject to income tax or

So I married an American ...

Davis LLP
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Canada, USA
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February 27 2013

The good news is that it is definitely better than marrying an axe muderer, but there may be "issues"

2013: a window of opportunity for S corporation asset sales

Bryan Cave LLP
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Canada, USA
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February 12 2013

In general, when an S corporation sells its assets, the gain on sale flows through to, and is reportable by, the shareholders and is not subject to a

Canada and U.S. announce agreement regarding PE attribution of income principles under Canada-U.S. Treaty

Gowling Lafleur Henderson LLP
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Canada, USA
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January 10 2013

The 5th Protocol to the Convention Between Canada and the United States of America with Respect to Taxes on Income and Capital (Canada-U.S. Treaty and

CRA considers US LLC and Canadian branch tax

Thorsteinssons LLP
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Canada, USA
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January 7 2013

The CRA does not consider a US limited liability company (LLC) itself to be a resident of the US for purposes of benefits under the Canada-US tax treaty

CRA comments on US company holding inventory in Canada

Thorsteinssons LLP
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Canada, USA
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January 7 2013

In 2012-0438691E5, the Canada Revenue Agency (CRA) considered a US corporation (US Co) that shipped inventory to an unaffiliated customer's warehouse in

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Search results

Overview of limitation on benefits article in Canada-U.S. Tax Treaty

CRA confirms tax treatment of US downstream absorptive merger

Recent developments for the fourth quarter 2012

The (far) reach of US tax evasion laws

Goin' South: planning to avoid unexpected southern exposure

So I married an American ...

2013: a window of opportunity for S corporation asset sales

Canada and U.S. announce agreement regarding PE attribution of income principles under Canada-U.S. Treaty

CRA considers US LLC and Canadian branch tax

CRA comments on US company holding inventory in Canada

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