International tax alert archive

2020

• February 19, 2020: Taxpayer victory in Alta case leaves important questions unanswered

2018

• June 12, 2018: Regulation 105 withholding – a new simplified process

2017

• June 12, 2017:  Signing of MLI to modify bilateral tax treaties

2016

• September 20, 2016: New international tax legislation
• April 4, 2016:  International measures in federal budget, including expansion of “back-to-back” rules

2015

• October 23, 2015:  Final report on BEPS Action 2: Neutralizing the effects of hybrid mismatch arrangements
• October 14, 2015: Final report on BEPS Action 5: Countering harmful tax practices more effectively, taking into account transparency and substance
  
• October 13, 2015:  Final report on BEPS Action 7: Preventing the artificial avoidance of PE status
• October 7, 2015: Final report on BEPS Action 4: Interest deductions and other financial payments
  
• October 5, 2015: BEPS Actions: An overall perspective
  
• May 20, 2015:  BEPS Action 7: Preventing the artificial avoidance of permanent establishment status
• April 14, 2015:  BEPS Action 3:  Strengthening CFC rules
• April 8, 2015:  BEPS Action 12: Mandatory disclosure rules

2014

• December 11, 2014: BEPS update - PE status, treaty abuse
• September 24, 2014: BEPS Action 1: Address the tax challenges of the digital economy
• September 22, 2014: BEPS Action 15: Developing a multilateral instrument to modify bilateral tax treaties
• September 22, 2014: BEPS Action 6: Preventing the granting of treaty benefits in inappropriate circumstances
• September 19, 2014: BEPS Action 5: Harmful tax practices
  
• September 18, 2014: BEPS Action 2: Hybrid mismatch arrangements
  
• September 9, 2014: New proposed legislation on cross-border financing and foreign affiliate dumping
• April 24, 2014: Federal Court of Appeal limits scope of Canadian foreign affiliate anti-avoidance rule in Lehigh
• April 4, 2014: OECD BEPS Action 2: Hybrid mismatch arrangements
• April 1, 2014: OECD BEPS Action 1: The digital economy
• March 25, 2014: OECD BEPS Action 6: Preventing treaty benefits in inappropriate circumstances
• February 20, 2014: Inbound financing and anti-treaty shopping measures

2013

• October 16, 2013: Canada-Malaysia tax treaty update
• May 31, 2013: Tax Court rules on scope of Canadian foreign affiliate anti-avoidance rule in Lehigh

2012

• November 20, 2012: Hong Kong and Canada sign income tax agreement
• October 26, 2012: Canadian government reintroduces “upstream loan” rules and other foreign affiliate proposals
• October 17, 2012: Canadian government introduces revised budget proposals on foreign affiliate “dumping”
• August 15, 2012: Canadian government releases revised budget proposals on foreign affiliate “dumping”
• March 29, 2012: Canadian budget impacts investment in foreign affiliates by Canadian subsidiaries
• February 28, 2012: Velcro Canada wins beneficial ownership case

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