Orbitax Tax News & Alerts
Canada's Tax news & updates from Orbitax and partners
Canada Tax News
Treaty between Mexico and Canada – details
Amendment to treaty between China (People's Rep.) and Canada
Treaty between Korea (Rep.) and Canada signed
Proposed legislation to eliminate double taxation of dividends paid by large Canadian corporations to Canadian individual shareholders
Treaty between Finland and Canada – details
Budget 2006 highlights
French Guideline on treaty treatment of Canadian mutual funds in securities published
The Competent Authorities of Canada and the United States have signed a memorandum of understanding (MOU) setting out the principles, guidelines and procedures to be followed in resolving factual disagreements in mutual agreement cases under the 1980 US-Canada income tax treaty. The MOU was signed on 23 December 2005 and follows the MOU signed on 3 June 2005 that formalized the mutual agreement procedure (MAP) for resolving cases of double taxation under the treaty. It also follows the announcement by the US Internal Revenue Service (IRS) and the Canada Revenue Agency (CRA) on 8 December 2005 that they had reached agreement on procedures for resolving factual disputes in the MAP process.
Tax Court finds anti-avoidance rules not violated
Tax Court of Canada applies tie-breaker rules in CanadaKorea (Rep.) tax treaty to determine residence status
The protocol, signed on 3 September 2002 to the France and Quebec income tax treaty (entente fiscale) of 1 September 1987, entered into force on 1 August 2005. The purpose of this protocol is to harmonize the France-Quebec treaty with the modifications made in the protocol signed on 30 November 1995 to the France-Canada treaty.
Revenue Agency releases transfer pricing memorandum on bundled transactions
As from 1 January 2006, the 2003 income tax treaty, signed on 8 October 2003, will replace the 1966 income tax treaty.
The new income and capital tax treaty between Canada and Romania, signed on 8 April 2004, entered into force on 31 December 2004. The new treaty generally applies from 1 January 2005.
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