Tax Advisory Services

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...

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...

Flexibility in the financial market in response to major changes

This year, financial market participants have been subject to many unprecedented changes that have forced them to show a great deal of flexibility....

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...

Update on implementation of the Multilateral Instrument in Canada

Canada is in the process of ratifying the Multilateral Instrument into Canadian law through Bill C-82, which is currently at third reading in the...

Canada tables NWMM to ratify MLI; Updates MLI reservations

Canada takes next step toward ratifying the MLI (to implement certain tax treaty changes), and removes some of its prior reservations. Learn more.

Federal Budget Briefing 2018

A summary of the significant tax proposals included in Budget 2018. Find out how these tax changes will affect Canadians and Canadian businesses.

CRA releases new guidelines for GST voluntary disclosures

On December 13, 2017, the Canada Revenue Agency released a revised update of its memorandum on the GST/HST voluntary disclosure program.

Government of Canada tests the limits under the Income Tax Act in 2017

In 2017, the Canada Revenue Agency (the CRA) pursued litigation which tested the limits of its powers under the Income Tax Act.

New PPT rule in the OECD’s Multilateral Instrument to displace Canadian GAAR?

Canada and many other countries have signed the OECD’s Multilateral Instrument (MLI). Once in effect, the MLI will add a broad anti-avoidance rule...