Canada Intent on Stoppin’ the Shoppin’ and More

Auteur : Michael N. Kandev

Disponible en anglais seulement.

Canada’s federal budget for 2014 proposed a rule intended to curtail treaty-shopping: the practice of structuring multinational businesses to take advantage of more favourable tax treaties available in certain jurisdictions. This article presents a number of scenarios to describe how application of this proposed rule would play out in differing circumstances, exposing potential problems that might ultimately discourage foreign investment.

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Federal Court of Appeal Says Funding Services Not Subject to GST/HST

4 oct. 2019 - Traduction en cours. 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...