Category: Canada

Canada: COVID-19 Just Made Transfer Pricing More Difficult

The COVID-19 pandemic has made the lives of hundreds of millions of people around the world uncertain, wreaking havoc on all aspects of our daily lives. Governments and taxing authorities are grappling with not only how to keep the broader macroeconomy viable over the short run, but also how to bring the economy back to fiscal balance in the medium and longer term. In an article published by the Gowling WLG Transfer Pricing & Competent Authority Group entitled "CRA Audit Activity: The Calm before the Storm?", it was hypothesized that the Canada Revenue Agency ("CRA") would likely step up audit activity, after the COVID-19 episode is finally behind us, to reign in government deficits. ... - Continue reading

Canada: Treaty Shopping: MIL, MLI And ALTA Things In Between

On February 12, the Federal Court of Appeal (FCA) released its decision in The Queen v. Alta Energy Luxembourg S.a.r.l.1 (Alta Energy), a case that represents an attempt by the Canadian tax authority to relitigate the issue of whether Canada’s domestic general anti-avoidance rule (GAAR) can apply to curtail so-called “treaty shopping”.2   ... - Continue reading

Canada: Transfer Pricing: What’s New In Canada (Part II)

Transfer pricing disputes in Canada have, predominately, been resolved through either a request for competent authority assistance under the Mutual Agreement Procedure ("MAP") of a treaty, or, to a much lesser extent, through the notice of objection process with CRA Appeals.  Regardless of the recent increase in transfer pricing cases being brought before the Courts, the MAP will likely continue to be the dispute resolution process most often utilized by a Canadian corporation in transfer pricing cases because, in the absence of a 100% reversal of a transfer pricing adjustment by either CRA Appeals or a Canadian court, economic double taxation may still exist as a consequence of the CRA upward transfer pricing adjustment. The correlative relief provided by the treaty partner under a MAP settlement resolves that double taxation. ... - Continue reading

Canada, Switzerland ratify instrument to tackle tax avoidance

Canada and Switzerland on August 8 deposited with the OECD their instruments of ratification for the Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS MLI). The BEPS MLI, negotiated by over 100 countries and jurisdictions, updates the existing network of tax treaties and… – Continue reading

Canadians for Tax Fairness concerned about inaction on Panama Papers

It is estimated that the use of tax havens is costing federal and provincial governments at least $7.8 billion in lost tax revenue. Low and middle income Canadians are the ones paying for that missing $7.8 billion in tax revenue. Ottawa (11 Aug. 2016) — The leak of the Panama… – Continue reading

Canada: With Recent Regulatory Developments, Canadian Business Interest In Cayman Will Grow

Canada is home to some of the largest multinational corporations in the world, a bustling pension fund and private equity industry, and growing numbers of alternative investment, real estate, and insurance shops. With dynamic industry and growth in the region, Canadian business leaders are leveraging Cayman as a financial centre to help… – Continue reading

Metro Vancouver developer and builder sentenced for tax evasion

A developer and builder based in Anmore has been found guilty of tax evasion and making false statements under the Income Tax Act, the Canada Revenue Agency (CRA) announced on Friday. According to the CRA, Willi Isaak was sentenced to pay a $23,100 fine, after being found guilty on two… – Continue reading

Corporate Canada’s Pile of Cash in Offshore Tax Havens Has Hit $353 Billion For the First Time in History

Luxembourg, Barbados and Bermuda are three of Canada’s top five destinations in the world for corporate cash After exploding to record levels under Stephen Harper’s Conservative government, the amount of money Corporate Canada is funneling through offshore tax havens has hit a new all-time high. According to data newly released… – Continue reading

Tax Netflix and other e-commerce companies, say Canadians and CRA professionals

OTTAWA, Feb. 21, 2019 (GLOBE NEWSWIRE) — The federal government needn’t worry about a consumer backlash to a sales tax on Canadians’ Netflix accounts, if newly released results from an Environics Research poll and a separate survey of Canada Revenue Agency (CRA) tax professionals are any indication, says the Professional… – Continue reading

1.6 million Canadian banking records shared with IRS

CRA now transferring 600,000 banking records per year under controversial information sharing agreement The Canadian government has shared more than 1.6 million Canadian banking records with the U.S. Internal Revenue Service since the start of a controversial information-sharing agreement in 2014, CBC News has learned. In 2016 and again in… – Continue reading

Canada should invest more to prevent tax evasion, say Canadians and CRA tax professionals

OTTAWA, Dec. 03, 2018 (GLOBE NEWSWIRE) — A large majority of Canadians (77%) agree “It would be a good investment for the Government of Canada to allocate more resources towards preventing tax evasion and avoidance,” according to a recent Environics Research poll. The poll was commissioned by the Professional Institute… – Continue reading

FBR urged to clarify taxability of foreign rental income

There is confusion among taxpayers regarding taxability of foreign rental income in Pakistan and filing of income tax returns in view of avoidance of double taxation treaties signed between Pakistan and UAE, UK and Canada. A leading tax consultant Shahid Jami has approached the Federal Board of Revenue (FBR) for… – Continue reading

Canada: Common Reporting Standard Is Now Fully In Effect – If You Have Been Hiding Funds Or Assets Offshore, Now Is The Time To Disclose

Introduction – Offshore funds and Canada Revenue Agency’ reach Gone are the days when offshore bank accounts were outside the Canada Revenue Agency (CRA)’s reach. With the advent of the Common Reporting Standard (CRS), CRA automatically receives financial information of Canadian taxpayers who own bank accounts or assets in other… – Continue reading

Canada’s Trudeau Announces $10.5-Billion Fiscal Stimulus to Compete With US

The cabinet of Canadian Prime Minister Justin Trudeau is set to implement tax cuts for the nation’s businesses, which, along with the announced plans to reduce regulation, are highly reminiscent of the economic policies of Canada’s southern neighbour. Kristian Rouz — Canadian Prime Minister Justin Trudeau has unveiled an ambitious… – Continue reading