Canada Tax News
Government releases draft legislation to implement remaining Budget 2007 tax measures
Fifth protocol to treaty between Canada and US – details
Treaty between Canada and Columbia – negotiations
OECD releases revised draft of Part IV (Insurance) of the Report on Attribution of Profits to Permanent Establishments
Treaty between Canada and Luxembourg – Canadian Federal Court of Appeal upholds Tax Court decision on non-applicability of general anti-avoidance rule to sale of shares
Implementation of key Budget 2007 measures
Anti-tax-haven initiative
Discussion draft on application and interpretation of non-discrimination article of OECD Model – details
Treaty between Canada and Greece – negotiations
Revised Commentary on Article 7 of OECD Model released
Treaty between Mexico and Canada ratified
Budget 2006 tax measures fully implemented
Budget 2007 highlights
Final Report on Improving the Resolution of Tax Treaty Disputes
Report on Attribution of Profits to PEs released
Treaty between Finland and Canada enters into force
Treaty between Canada and Korea (Rep.) enters into force
Treaties with the United States and Canada considered
Finland ratifies treaty between Finland and Canada
Treaty between Canada and Malaysia – negotiations to start
Treaty between Mexico and Canada – details
Treaty between Korea (Rep.) and Canada signed
Amendment to treaty between China (People's Rep.) and Canada
Treaty between Finland and Canada – details
Proposed legislation to eliminate double taxation of dividends paid by large Canadian corporations to Canadian individual shareholders
Budget 2006 highlights
French Guideline on treaty treatment of Canadian mutual funds in securities published
The Competent Authorities of Canada and the United States have signed a memorandum of understanding (MOU) setting out the principles, guidelines and procedures to be followed in resolving factual disagreements in mutual agreement cases under the 1980 US-Canada income tax treaty. The MOU was signed on 23 December 2005 and follows the MOU signed on 3 June 2005 that formalized the mutual agreement procedure (MAP) for resolving cases of double taxation under the treaty. It also follows the announcement by the US Internal Revenue Service (IRS) and the Canada Revenue Agency (CRA) on 8 December 2005 that they had reached agreement on procedures for resolving factual disputes in the MAP process.
Tax Court finds anti-avoidance rules not violated
Tax Court of Canada applies tie-breaker rules in CanadaKorea (Rep.) tax treaty to determine residence status
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