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Eric Koh

Gowling WLG

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New limitation on benefits provisions in Canada's tax treaties - A step too far?

Canada - July 9 2013 Canada's tax treaties with foreign countries routinely include a variety of anti-abuse or treaty shopping provisions aimed at those structures or...

Jim Wilson.


Further commentary by Canada Revenue Agency on paragraph 149(1)(I) - profit motive and distribution of income to members

Canada - February 8 2013 Canada Revenue Agency ("CRA") recently released Document 2012-0455501I7 on whether certain transactions and investments jeopardized a corporation's...


Canada's new tax treaty with Hong Kong: 10 key aspects

Canada, Hong Kong - January 18 2013 On Nov. 11, 2012, after relatively swift negotiations, the Government of Canada signed a tax treaty with the Government of the Hong Kong Special...

Jim Wilson.


Moving in and out of Canada - Proposed amendment to definition of “eligible relocation” may restrict deduction for moving expenses

Canada - November 22 2012 Subsection 62(1) of the Income Tax Act (the “Act”) provides that, subject to certain conditions and limits, a taxpayer may deduct moving expenses that are paid by the taxpayer in respect of an “eligible relocation,” which is defined in section 248 of the Act....


New disclosure requirements and added relief for U.S. taxpayers with undisclosed foreign assets

USA, Canada - March 9 2012 The U.S. government has recently embarked on an aggressive campaign to reduce international tax evasion by U.S. citizens or permanent residents with undisclosed income and assets located in foreign countries....