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Canadian COVID-19 Guidelines – International Tax
On April 1, 2021, Canada Revenue Agency (“CRA”) updated its guidance with Part VII – Supplemental Guidance[1] which provides further relief from Canadian residency and Canadian permanent establishment for certain non-residents of Canada and businesses by extending the relief period to December 31, 2020. The updated guidelines also provide an alternate method for cross-border employment income […]
Mandatory Disclosure for Aggressive Tax Planning (ATP) – Revenu Québec
March 29, 2021Prepared 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 […]
U.S. Taxes Non-U.S. Corporation on Gross U.S. Business Income
March 4, 2021The 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 […]
Global Intangible Low-Tax Income (GILTI) Explained
January 7, 2021In 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 […]