International Tax International Tax

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...

Canadian government eliminates facilitation payments exclusion in the Corruption of Foreign Public Officials Act

As of October 31, 2017, facilitation payments will no longer be excluded from the bribery offence under Canada’s Corruption of Foreign Public...

Federal Court of Appeal’s Univar decision provides guidance on how to apply the GAAR

On October 13, 2017, the Federal Court of Appeal released its highly anticipated decision in Univar, finding that the General Anti-Avoidance Rule...

New world for leveraged U.S. real estate partnerships

For Canadian entities seeking to access the booming U.S. real estate market or to diversify their global real estate holdings, strategically...

The U.S. “Big Border Tax”: A primer for Canadians

If enacted, the Blueprint proposals would represent a tectonic shift in the U.S. taxation system by effectively repealing the income tax and...