Methanex Case and International ‘Treaty Shopping’ in Search of Better Tax Breaks: Lessons for Canadian Corporations
Overview: Court Confirms Key Principles around Beneficial Ownership, Corporate Residence,…
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How an Heir was Taxed 75% by the UK, Spain on his Inheritance (Just Crumbs Left) and How Tax Treaties Prevent Double Taxation
Recently, an X [formerly Twitter] user shared a post about…
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How the Mutual Agreement Procedure (MAP) Can Help Businesses and Individuals Resolve Cross-Border Tax Problems, plus tips from Canadian Tax Lawyer
Introduction: The Mutual Agreement Procedure (MAP) Is A Dispute Resolution…
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Beware CRA’s Ability to Share Information with Foreign Tax Authorities Using Tax Information-Exchange Provision In Bilateral Tax Treaties And Tax Information Exchange Agreements: A Canadian Tax Lawyer’s Primer
Introduction: CRA Has the Ability to Exchange Tax-related Information with…
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How To Interpret a Tax Treaty – Guidance from a Canadian Tax Lawyer
What is a tax treaty A tax treaty is a…
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Canadian Lawyer Analysis – The Supreme Court of Canada Holds that Tax Treaty Shopping Does Not Constitute Abuse Within the Meaning of the General Anti-Avoidance Rule (Canada v. Alta Energy Luxembourg S.A.R.L.)
Two Spectrums in the Canadian Tax Planning Behaviour There are…
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Tax Treaty Residence Determination: Canadian Tax Lawyer Guide
Tax Residence and Tax Treaties There are two factors that…
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Canadian Citizen with a US Greencard
If you are a Canadian citizen with a US greencard…
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Treaties Impacting on Taxation: A Canadian Tax Lawyer’s Perspective
Taxation has become an increasingly global issue as people, money…
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Tax Treaty
There are income tax treaties between Canada and numerous countries…
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