Jan. 31, 2025 - First published by the Canadian Tax Foundation in (2024) 72:4 Canadian Tax Journal. Treaty Provides Unique Benefits To Canadians Migrating To The United States Canadians who emigrate to the United States or elsewhere face many decisions and considerations...
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Canada Expands Back-to-Back Regime: Examining the Character Substitution Rules
In this article from Tax Notes International, Davies partner Michael Kandev explains Canada’s latest attempt to fight treaty shopping through an expanded back-to-back regime, focusing on the regime’s complex and sometimes mysterious character substitution rules.
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Federal Court of Appeal Confirms CRA Can Collect Arrears Interest Despite Absence of a Tax Debt
Dec. 04, 2024 - The Federal Court of Appeal (FCA) recently dismissed the Bank of Nova Scotia’s (BNS) appeal and upheld the Canada Revenue Agency’s (CRA) practice of charging arrears interest on a non-existent tax debt where audit adjustments increase taxable income that is offset by the carryback of a loss...
