International Tax International Tax

CUSMA comes into force and Biden is elected President: Calmer seas ahead for U.S.-Canada trade?

After a rocky 2019, global trade faced another challenging year in 2020 with the COVID-19 pandemic and continued aggressive trade actions by the...

COVID-19 tax measures and proposed international tax reform

Two significant tax developments in 2020 were Canada’s measures in response to COVID-19 and Canada’s participation with the OECD’s pursuit of...

From treaty shopping to FAPI and transfer pricing: Notable international tax cases

Three decisions of the Federal Court of Appeal (FCA) released during the COVID-19 pandemic have caused renewed interest in certain fundamental...

OECD releases blueprint reports on international tax reform (Pillar One and Pillar Two) and launches public consultation

The OECD recently released blueprint reports on Pillar One and Pillar Two and launched a public consultation process on its two-pillar approach to...

One of these things is not like the other: A Canadian amalgamation is similar to a Delaware merger, but there are critical differences

A recent decision of the Delaware Superior Court (the Court) serves as a useful reminder that there are important differences between a Canadian...

Canadian government temporarily extends national security review timelines

The Minister of Innovation, Science and Industry issued a Ministerial Order pursuant to the Time Limits and Other Periods Act lengthening certain...

Canada ratifies CUSMA: Tax implications

On Friday, March 13, Canada ratified the trade agreement between Canada, the United States of America and the United Mexican States (CUSMA).

B.C. announces newly extended registration requirements for its provincial sales tax

In its 2020 Budget and Fiscal Plan, dated February 18, 2020, British Columbia (B.C.) announced that it would be imposing newly extended registration...

OECD provides additional detail on Pillar One proposal in update on international tax reform – Seeking consensus-based solution in 2020

On January 31, 2020, the OECD/G20 Inclusive Framework on BEPS released the Statement by the OECD/G20 Inclusive Framework on BEPS on the Two-Pillar...

Should Canadian entrepreneurs incorporate in the United States?

Canadian entrepreneurs often look to the United States for the future financial prospects of their startups, primarily through development funding...