Carrie Smit, a partner with Goodmans LLP, Toronto, analyzes the Canadian Federal Court of Appeals March 4 decision in The TDL Group Co. v. The Queen, which concluded that a Canadian company is entitled to deduct interest on an intercompany loan used to acquire shares of its US subsidiary. . .
The OECD has today published peer review reports that critique the tax treaty dispute resolution process of six countries: United States, Belgium, Canada, the Netherlands, Switzerland, and the United Kingdom. The peer review was conducted by the “Inclusive Framework on BEPS,” comprised of over 100 countries that have pledged to . . .
Canadian and US tax officials on June 7 signed a competent authority agreement detailing the planned exchange of annual country-by-country reports on the tax affairs of multinational . . .
Kabir Jamal, an attorney with Goodmans LLP, Toronto, discusses statements made by Canadian Revenue Agency officials at a conference last week announcing the agency’s decision to classify Florida and Delaware LLPs and LLLPs as corporations for income tax purposes . . .
The US IRS today released its annual statistics on the performance of its Advance Pricing Mutual Agreement (APMA) program, revealing that the tax agency signed . . .
Wheaton Precious Metals™ Corp. (“Wheaton” or the “Company”) is very pleased to . . .
More: Mining.com, Streetwise Reports.
Canada and Switzerland on December 23 exchanged notes for automatic exchange of information in tax . . .
Eight countries are working on a new program to jointly review large multinationals’ tax affairs and, if appropriate, provide assurances to the multinational that it will not likely be audited in those jurisdictions with respect to specific tax risks, officials said June 6 in Washington at a conference sponsored by the OECD, USCIB, . . .
Goodmans LLP tax attorney, Kabir Jamal, provides an analysis of the international tax proposals in the Canadian government’s draft tax bill, issued July 29, including measures that address foreign exchange gains on foreign-currency debt, back-to-back loan and royalty arrangements, and country-by-country reporting . . . .
Officials from six countries today signed a multilateral agreement that sets out the parameters for the automatic exchange of country-by-country reports on large multinational corporations. China, India, Canada, Iceland, Israel, and New Zealand joined 33 other countries that have . . .
Hong Kong signed treaties with six countries on March 16 for the automatic exchange of financial account information (AEOI) in tax. . .
The Canada Revenue Agency on April 22 released a new circular describing procedures to obtain an advance income tax ruling . . .
Taiwan and Canada have signed an arrangement to avoid double taxation, Canada’s Department of Finance announced today. The . . .
Canada and the UK have signed an agreement specifying the procedures for arbitration of tax disputes between the two nations, Canada’s Department of Finance . . .
Finance Minister Joe Oliver on October 10 tabled in the House of Commons tax proposals to implement the government’s budget and about a dozen tax proposals not included in the budget.
International tax . . .
The Australian Taxation Office has ruled, in a May 30 interpretative decision. . .
India, Australia, Canada, on June 3 signed the OECD common reporting standard multilateral competent authority agreement, paving the way for automatic exchange of information by the countries’ tax administration, according to press releases issued by the countries’s governments. Costa Rica, Indonesia, and New Zealand . . .
Spain and Canada have signed a protocol their update their tax treaty, the Spanish government announced on November 18. The new protocol would update . . .
The UK and Canada, on July 21, signed a protocol and interpretative protocol to the countries’ double tax convention. The agreement provides for a zero rate of withholding tax on dividends to registered pension funds and updates treaty provisions on business profits, the mutual agreement procedure and arbitration, exchange of information, and assistance in collection. Protocol and Interpretative Protocol (PDF 63K), Release
Canadian billionaire Eugene Melnyk has confirmed that, in 2012, he made a presentation to U.S. tax authorities as an “official whistleblower,” alleging that Valeant Pharmaceuticals, formerly a U.S. company, should have continued to pay U.S. tax following its merger with Canada-based Biovail and change of headquarters to Canada, writes Nicolas Van Praet of the Financial Post. See, Financial Post.
CPA Brandon Vucen and U.S. attorney Alex Manasuev on November 11 announced they have formed U.S. Tax IQ, a tax firm headquartered in Toronto, Canada, that focuses on cross-border tax issues. Release
A Canadian subsidiary of Skechers USA, the footwear company, must add research, design, and development (R&D) payments made to its parent under a cost sharing agreement (CSA) to the customs value of imported footwear supplied by its parent, Canada’s Federal Court of Appeals has ruled in a March 2 decision. In so concluding, the court upheld the Canadian . . .
Justice Patrick Boyle has recused himself from deciding all remaining issues in McKesson Canada Corporation’s transfer pricing proceedings in the Tax Court of Canada, including costs and confidentiality issues . . .
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