Selected tax policy and administrative developments.
The OECD published a draft discussion paper outlining proposed changes to its Transfer Pricing Guidelines relating to management fees and head office expenses.
The OECD published a 26-page draft discussion paper on October 31, 2014 outlining proposed changes to the definition of permanent establishment (PE) in Article 5 of the OECD Model Treaty.
Oil and gas and mining companies operating in Canada will soon be required to publish annual reports detailing tax and other payments they make to all levels of domestic and foreign governments.
If your estate plan includes creating a trust in your will or you are a trust beneficiary or an estate trustee, you may be affected by the new legislation to tax certain trusts at the top marginal tax rate rather than the lower graduated tax rates.
Time is quickly running out for participants in joint ventures that include nominee corporations or bare trusts to take steps to benefit from the CRA’s GST/HST temporary administrative “tolerance” policy.
Today Prime Minister Stephen Harper announced tax changes that will provide tax savings to families starting in 2014.
Your Canadian company may soon have to start filing closely related group elections with the CRA.
British Columbia introduced its much anticipated legislation for a new two-tier tax on net income from liquefied natural gas (LNG) facilities in British Columbia on October 21, 2014.
Americans and green card holders in Canada with Canadian retirement plans now have fewer U.S. forms to file each year.
The OECD released its highly anticipated recommendations on seven high profile international tax topics as part of its Base Erosion and Profit Shifting (BEPS) initiative on September 16, 2014.
Canada recently agreed to amend its tax treaty with the United Kingdom (U.K.), and a Protocol between the two countries was signed on July 21, 2014.
Ontario’s newly re-elected Liberal government reintroduced the 2014 Ontario budget on July 14, 2014.
If you are required to file a U.S. return and have offshore assets, you may be able to use the IRS’s expanded streamlined filing compliance.
Canadian entities that could be subject to the U.S. FATCA, which takes effect July 1, 2014, will be interested in the CRA’s new guidance on Canada’s IGA with the United States.
If you are required to file Return T1135, "Foreign Income Verification Statement" for the 2013 tax year, you only have a short time left to gather information on your foreign investments before the July 31, 2014 due date.
If you are involved in preparing financial reports for corporations or other organizations, certain 2014 Canadian income tax changes may need to be reflected in your interim-period financial statements under IFRS, ASPE or U.S. GAAP.
Participants in joint ventures that include nominee corporations or bare trusts have a short period of time to benefit from the CRA’s GST/HST temporary administrative policy.
Fund managers and insurance companies (“managers”) that are not registered for QST may need to file a specific new QST return no later than June 30, 2014.
Canadian entities subject FATCA need to ensure that they are ready for these rules now that Canada has implemented an IGA with the United States.
Corporations that engage in certain cross-border transactions will be interested in the CRA’s guidance on its contemporaneous documentation requests.
Today, Quebec's Minister of Finance and the Economy, Carlos Leitão delivered the province’s 2014 budget.
Today Ontario Finance Minister Charles Sousa delivered the province’s 2014 budget.
The CRA has extended the filing deadline for 2013 personal tax returns to May 5, 2014 after it temporarily shut down its online services to fix a critical security issue.
Multinational corporations that could be subject to additional transfer pricing documentation and country-by-country reporting will be interested in the OECD latest communications in this area.
Canadian businesses that operate in the digital economy will want to follow the recent high-profile initiatives by the Organisation for Economic Co-operation and Development (OECD) in this area.
Today P.E.I. Finance Minister Wesley Sheridan delivered the province’s 2014 budget.
Canadian multinationals and foreign corporations investing in or through Canada will be most interested in the Organisation for Economic Co-operation and Development’s (OECD) new discussion draft on "Prevent treaty abuse" (the paper).
Canadian trusts that will be treated as “foreign financial institutions” under the U.S. FATCA will want to closely follow legislative developments now that the Canadian government has tabled legislation implementing the IGA in Canada.
Canadian companies who have international structures that involve the use of either a hybrid instrument or a hybrid entity will want to closely follow the recent high-profile initiatives by the OECD.
Today Nova Scotia Finance Minister Diana Whalen delivered the province’s 2014 budget.
Today Newfoundland and Labrador Finance Minister Charlene Johnson delivered the province’s 2014 budget.
Oil and gas and mining companies operating in Canada may have to act quickly to meet rigorous new financial and tax transparency reporting standards.
Today Saskatchewan Finance Minister Ken Krawetz delivered the province’s 2014 budget.
Today Manitoba Finance Minister Jennifer Howard delivered the province’s 2014 budget.
Today Alberta Finance Minister Doug Horner delivered the province’s 2014 budget.
Canadian taxpayers, including Canadian-based multinationals, with arm’s-length commercial lending arrangements could be unexpectedly impacted by the 2014 federal budget’s new thin capitalization and withholding tax proposed anti-avoidance measures.
A recent report issued by the CRA indicates that a significant number of incorporated non-profit organizations (NPO) in Canada do not comply with the rules in the Income Tax Act that provide for an exemption from tax on their activities.
If you own certain types of foreign property you will be interested in new transitional filing relief announced by the CRA which should help you complete Form T1135 on a timely basis for the 2013 tax year.
Foreign-based multinationals and foreign corporations investing in or through Canada will want to closely follow developments of the 2014 federal budget’s proposed rule to prevent “treaty shopping”.
Certain investment funds that are trusts may be subject to unexpected and potentially harsh tax consequences from a measure first introduced with the 2013 federal budget that extended the tax loss restriction rules to trusts.
The Minister of Finance and the Economy, Mr. Nicolas Marceau, tabled earlier today the 2014-2015 Québec Budget in which he still aims at a balanced Budget for 2015-2016.
Today British Columbia Finance Minister Michael de Jong delivered the province’s 2014 budget.
Canada’s 2014 federal budget, delivered on February 11, 2014, made several new announcements and proposals that appear to strengthen Canada’s intentions to address tax base erosion and profit shifting by multinational corporations.
Finance Minister Jim Flaherty delivered the government’s 2014 federal budget on February 11, 2014.
Participants in joint ventures will be relieved to learn that the CRA has issued a temporary administrative policy not to assess GST/HST in certain circumstances.
Canadian entities that will be treated as Foreign Financial Institutions must now consider their potential requirement to register with the U.S. IRS under the U.S. FATCA now that an IGA between Canada and the U.S. was signed on February 5, 2014.
Today New Brunswick Finance Minister Blaine Higgs delivered the province’s 2014 budget.
Multinational corporations may have to consider additional reporting requirements under the OECD initial draft of its revised guidance on transfer pricing documentation and country-by-country reporting.
Finance Minister Jim Flaherty has announced that he will deliver the Conservative government’s 2014 federal budget on February 11, 2014.
Canadian multinational companies may want to note the implications of the recent transfer pricing case McKesson Canada Corp.
Today the CRA announced it will take a new approach to improving tax compliance among small and medium sized businesses.