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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

U.S. tax and filing obligations for Canadians

Miller Thomson LLP
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Canada, USA
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June 13 2012

Canadian individuals are well aware of the April 30 tax filing deadline for Canadian income tax returns

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

Miller Thomson LLP
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Canada, USA
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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”

Gifts to U.S. Charities and the Availability of Charitable Tax Credits An Unusual Situation

Miller Thomson LLP
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Canada, USA
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September 30 2011

The Canada Revenue Agency recently released a technical interpretation with respect to an interesting and somewhat unusual fact scenario

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

Miller Thomson LLP
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Canada, USA
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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

Is the provision of fertility charitable?

Miller Thomson LLP
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Canada, USA
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December 31 2010

At the end of September of this year, the City of Toronto had the pleasure of hosting the American Bar Association Tax Conference

Tax Information Exchange Agreements - overview and update

Miller Thomson LLP
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Canada, USA
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October 5 2010

Most international tax treaties entered into by Canada include a tax information exchange provision (e.g., Article XXVII of the Canada-US Tax Treaty) that enables the Canada Revenue Agency (“CRA”) to obtain pertinent tax information about a particular taxpayer from a foreign country or jurisdiction

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
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Canada, USA
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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"

Canadian tax refunds for U.S. limited liability companies

Miller Thomson LLP
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Canada, USA
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July 9 2010

Before the Fifth Protocol amendments to the Canada-US Income Tax Convention (the Treaty), the Canada Revenue Agency (CRA) maintained that a fiscally transparent US limited liability company (LLC) was not entitled to Treaty benefits because the U

Some guidance from Canada Revenue Agency on application of Fifth Protocol to unlimited liability companies and limited liability companies

Miller Thomson LLP
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Canada, USA
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December 31 2009

On November 24, 2009, the Canada Revenue Agency (“CRA”) provided some guidance on certain issues related to the application of the new hybrid rules in the Fifth Protocol to the Canada-US Tax Treaty (the “Treaty”) to Canadian unlimited liability companies (“Canadian ULCs”) (i.e. Nova Scotia, Alberta and British Columbia ULCs) and US limited liability companies (“US LLCs”

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