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Unreported foreign property or income? Should you make a voluntary disclosure?

Canada - April 23 2014 Recently the Canada Revenue Agency (the "CRA") has stepped up its enforcement of Canadian tax laws as they relate to individuals that own foreign…

Thomas Brook.

Avoid a border dispute: know the tax implications of cross-border employment and assignments

Canada - March 31 2014 In the increasingly "borderless" world in which business operates, it's common for Canadian businesses to engage individuals from other countries to…

The Supreme Court of Canada rules in favor of taxpayers regarding retroactive rectification of documents and their enforceability against tax authorities

Canada - November 29 2013 On November 28, 2013, in the Services environnementaux AES Inc. case, the Supreme Court of Canada ("SCC") has confirmed a decision of the Qu&eacute…

Frédéric Barriault, François Barette, Nikolas Blanchette, Alan M. Schwartz, Kevin H. Yip.

Practical tax considerations: cross-border employment and assignments

Canada - April 17 2013 Subject to the application of a Tax Treaty, non-residents are subject to Canadian income tax on income from employment earned in Canada. The…

Payments to relinquish right to reinstatement likely taxable according to CRA

Canada - December 8 2011 In CRA Document No.: 2011-0421931E5, the Canada Revenue Agency (the "CRA") concluded that a payment made by an employer to relinquish an employee's potential right to reinstatement likely constituted a "retiring allowance," as defined in the Income Tax Act (Canada) (the "Act") and would, therefore, be taxable.

François Barette.