Category Archives: Tax treaties

CANADIAN FOREIGN TAX CREDITS AND TAX TREATIES-MYTH VS. REALITY

CANADIAN FOREIGN TAX CREDITS AND TAX TREATIES-MYTH VS. REALITY Ever since I can remember, I have heard people reiterate what appears to be a common misconception regarding the ability of Canadians to claim a credit, for foreign taxes that they pay, against their Canadian tax liability. This myth seems to be widespread among accountants who… Continue Reading

MARCH 22, 2016 CANADIAN FEDERAL BUDGET TARGETS TREATY SHOPPING AND OTHER PERCEIVED ABUSES

For many years now, the Canada Revenue Agency (“CRA”) and the Ministry of Finance seem to have been fighting a losing battle to combat what they perceive to be the abusive use of tax treaties to reduce Canadian taxes. In recognition of the concern regarding this area, the “General Anti-Avoidance Rule” (“GAAR”), found in section… Continue Reading