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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
- -
- 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
Overview of new Canada-Hong Kong Tax Treaty
- Miller Thomson LLP
- -
- 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
Cross-border tax: Canada-US Tax Treaty update CRA views on treaty entitlement on Canadian source income and profit for US LLC shareholders
- Miller Thomson LLP
- -
- Canada, USA
- -
- October 5 2010
The Canada Revenue Agency ("CRA") recently confirmed that it continues to maintain its long-standing position that a US limited liability company ("US LLC") that is treated as a fiscally transparent entity for US tax purposes is not entitled to treaty benefits under the Canada-US Tax Treaty, as amended by the Fifth Protocol ("Treaty"
Cross-Border and International Tax: new Canadian compliance requirements for non-residents of Canada
- Miller Thomson LLP
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- Canada
- -
- June 6 2011
Non-residents of Canada that are eligible for benefits under a tax treaty entered into between Canada and another country will now have to complete a declaration or provide equivalent information to avail themselves of any reduced rate of tax or exemption provided under the relevant tax treaty
Fifth Protocol to the Canada-U.S. Income Tax Treaty and unlimited liability corporations
- Miller Thomson LLP
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- Canada
- -
- October 20 2009
On December 15, 2008, the Fifth Protocol to the Canada-U.S. Income Tax Treaty (the “Treaty”) came into force
Key tax issues for the investment management industry
- Miller Thomson LLP
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- Canada
- -
- December 3 2009
In its final report released in December 2008 (Final Report), the Advisory Panel on Canada’s System of International Taxation (Advisory Panel) considered various international tax matters including, in particular, two key tax issues for the investment management industry (Industry), namely the exportation and importation of Canadian financial advisory services
Cross-border tax: Canada-US tax treaty update: CRA views on treaty benefits on dividends paid by Canadian ULC's
- Miller Thomson LLP
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- Canada
- -
- July 21 2010
Treaty benefits will generally be denied under the new anti-hybrid rule under Article IV(7)(b) of the Canada-US Tax Treaty (the "Treaty") in respect of any dividends paid on or after January 1, 2010 by Canadian unlimited liability corporations ("Canadian ULCs"
CRA guidance on whether Canadian captive service subsidiary constitutes PE of foreign parent
- Miller Thomson LLP
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- Canada
- -
- December 19 2011
Canada Revenue Agency (“CRA”) has recently issued a favourable advance income tax ruling (“ATR”) to the effect that a company that is a non-resident of Canada (“Foreign Parent”) would not be considered to be carrying on business in Canada through a permanent establishment (“PE”) within the meaning of a tax treaty where it has a Canadian service subsidiary which performs services only for Foreign Parent (“Canadian Captive Service Subsidiary”
Copthorne decision: Supreme Court of Canada unanimously applies GAAR
- Miller Thomson LLP
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- Canada
- -
- June 13 2012
In its most recent decision involving the application of the general anti-avoidance rule (the “GAAR”), under section 245 of the Income Tax Act (Canada) (the “Act”) a unanimous Supreme Court of Canada (the “SCC”) applied the GAAR to a complex series of transactions that culminated in what would otherwise have been a tax-free share redemption
The Lehigh Cement case - Canadian non-resident withholding tax on interest payments
- Miller Thomson LLP
- -
- Canada
- -
- October 5 2010
On May 17, 2010, the Federal Court of Appeal (“FCA”) rendered its judgment in Lehigh Cement Limited v. R., 2010 FCA 124 (“Lehigh”), in which it found that the transaction in issue entered into by the corporate taxpayer, Lehigh Cement Limited (“LCL”), did not result in a misuse of the Canadian non-resident withholding tax provision applicable to interest payments in subparagraph 212(1)(b)(vii) of the Income Tax Act (Canada) (the “Act”) such that the general anti-avoidance rule (“GAAR”) did not apply to the transaction
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- Jurisdiction - Canada
- Firm Name - Miller Thomson LLP
- Author - Lyne M. Gaulin
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