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Mandatory Disclosure for Aggressive Tax Planning (ATP) – Revenu Québec

Prepared by Andersen in Canada, Montréal Partner Patrick Coutu and Tax Manager Divya Katyal The Aggressive Tax Planning Research and Integrity Branch of Revenu Québec has recently issued a statement to broaden measures to combat aggressive tax planning. The disclosure obligations will now be extended to specified transactions by the Minister of Revenue published on […]

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U.S. Taxes Non-U.S. Corporation on Gross U.S. Business Income

March 4, 2021

The U.S. Tax Court issued an important decision in Adams Challenge (U.K.) Limited v. Commissioner (“Adams Challenge”) in January of 2021 that will have implications for Canadians conducting business in the U.S. This case adds an important insight regarding the scope of the non-discrimination provisions included in most U.S. tax treaties. The case provides a […]

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Global Intangible Low-Tax Income (GILTI) Explained

January 7, 2021

In our latest YouTube video, Andersen partners Warren Dueck and Steven Flynn explain GILTI, a U.S. tax on the earnings of non-US corporations owned by U.S. investors.  Warren and Steven cover how GILTI impacts U.S. persons, including those resident in Canada, who own Canadian and other non-U.S. corporations.  They discuss why effective tax planning is […]

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Canadian Tax Alert: 2020 Federal Fall Economic Statement

December 4, 2020

Prepared by Andersen in Canada, Montréal Partners Patrick Coutu and Simon Davari. On November 30, 2020, Canada’s Deputy Prime Minister and Federal Minister of Finance, Chrystia Freeland, presented the 2020 Federal Fall Economic Statement (Economic Statement). We are pleased to provide you the summary below of the tax announcements that were addressed in this statement: […]

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