Oct. 04, 2019 - In SLFI Group v Canada (2019 FCA 217), the Federal Court of Appeal (FCA) overturned a Tax Court of Canada (TCC) decision and ruled that a group of Canadian mutual funds (Funds) was not required to self-assess GST/HST on funding services provided by a U.S. entity, because these services were...
The BEPS Deliverables: A Macro Critique
Tax Notes International, Vol. 76, No. 7
The OECD’s crusade against base erosion and profit shifting will be remembered either as a well-coordinated campaign against abusive tax avoidance by large multinational enterprises or as a waste of vast amounts of time, resources, and energy for businesses, tax communities, and governments.
Aug. 22, 2019 - As outlined in our e-communications of May 21, 2019, and August 12, 2019, Québec’s Ministry of Finance has introduced new rules regarding the disclosure of nominee agreements. The new disclosure requirement is relevant to nominee agreements involving one or more parties that are subject to Québec tax...