fmc-law.com RSS Feeds - Publications - International Taxhttp://www.fmc-law.com/upload_net/rss/en/International_Tax.xmlThu, 31 May 2012 10:01:23 GMTen-us5The March 29, 2012 Canadian federal budget (the “Budget”) proposes a number of changes to Canada’s thin capitalization rules that may have significant implications to cross-border financing. Clients should review existing financing arrangements to assess the potential implication of these changes and must carefully consider proposed Canadian investments to ensure compliance with the new regime. Read more by clicking the download button.http://www.fmc-law.com/Publications/0512_Beefing_Up_Canada_Thin_Capitalization_Rules.aspxSun, 01 Apr 2012 06:00:00 GMThttp://www.fmc-law.com/Publications/0512_Beefing_Up_Canada_Thin_Capitalization_Rules.aspxFederal Budget 2012 This annual publication is produced by the National Tax Group of Fraser Milner Casgrain LLP (FMC), together with CCH.  This edition contains editorial comments regarding the tax proposals announced in the 2012 Federal Budget by the Honourable James M. Flaherty, P.C., M.P., Minister of Finance.  Tax Analysis Several FMC tax lawyers are on the Editorial Board of the CCH Canadian Tax Reporter, and even more are involved in writing the CCH tax commentary in the Reporter. On March 29, 2012, FMC tax lawyers and CCH participated in the Budget lockup to produce the CCH commentary on the Budget's tax measures. Following the lockup, the document was reviewed by members of FMC’s National Tax Group who also had the opportunity to provide their commentary. To view the Resolutions and CCH editorial commentary, please click here. Federal Budget Documents For complete budget documents, please click here. Read more by clicking on the download button.http://www.fmc-law.com/Publications/0312_Focus_On_Tax_Federal_Budget_2012.aspxThu, 29 Mar 2012 06:00:00 GMThttp://www.fmc-law.com/Publications/0312_Focus_On_Tax_Federal_Budget_2012.aspxThe Tax Court has once again considered the meaning of the phrase “beneficial owner” for purposes of the tax treaty between Canada and the Netherlands. It has also once again ruled in favour of the taxpayer in determining that a Dutch holding company was the “beneficial owner” of amounts received from a related Canadian company. On February 24, 2012, the Tax Court of Canada released its eagerly-anticipated decision in Velcro Canada Inc. v. Her Majesty the Queen, which addresses the applicable Canadian withholding tax rate in respect of cross-border royalty payments within a multinational corporate group. The decision comes almost four years after the Tax Court released its landmark decision in Prévost Car Inc. v. The Queen, which dealt with the identical treaty interpretational issue in the context of cross-border dividend payments. These decisions are relevant to any multinational enterprise using a foreign holding company as an investment/financing vehicle and provide considerable comfort concerning the tax effectiveness of such structures. Read more by clicking the download button.http://www.fmc-law.com/Publications/0212_Peters_Matthew_Beneficial_Owner_CRA_Assessment_of_Velcro_Does_Not_Stick.aspxMon, 27 Feb 2012 07:00:00 GMThttp://www.fmc-law.com/Publications/0212_Peters_Matthew_Beneficial_Owner_CRA_Assessment_of_Velcro_Does_Not_Stick.aspxIn this article, Jesse Brodlieb discusses the responses of the Canada Revenue Agency and Revenu Quebec to several questions on international tax matters that were discussed at the CRA Roundtable at the Canadian Tax Foundation’s 2011 annual conference. Among the issues discussed are: The Services Permanent Establishment Rule Convertible Debentures and Non-resident Withholding Tax Taxable Canadian Property Republished with permission. Read more by clicking the download button.http://www.fmc-law.com/Publications/1111_Brodlieb_Jesse_Canada_Revenue_Agency_Sheds_Light_International_Tax_Issues.aspxFri, 02 Dec 2011 07:00:00 GMThttp://www.fmc-law.com/Publications/1111_Brodlieb_Jesse_Canada_Revenue_Agency_Sheds_Light_International_Tax_Issues.aspxFederal Budget 2011 - Update       This annual publication is produced by the National Tax Group of Fraser Milner Casgrain LLP (FMC), together with CCH.This edition contains editorial comments regarding tax proposals announced in the first Federal Budget on March 22, 2011, and the second Federal Budget on June 6, 2011, by the Honourable James M. Flaherty, P.C., M.P., Minister of Finance.  Tax AnalysisSeveral FMC tax lawyers are on the Editorial Board of the CCH Canadian Tax Reporter, and even more are involved in writing the CCH tax commentary in the Reporter. On March 22, 2011, FMC tax lawyers and CCH participated in the Budget lockup to produce the CCH commentary on the Budget's tax measures. Following the lockup, the document was reviewed by members of FMC’s National Tax Group who also had the opportunity to provide their commentary.On June 6, 2011, the government did not conduct a Budget lockup, but instead made the Budget documents available at 4 p.m. Members of FMC's National Tax Group and CCH reviewed both the first and second Budget documents to provide updated and complete commentary. To view the Resolutions and CCH editorial commentary, please click here.Federal Budget Documents       For complete June 6 Budget documents, please click here. For complete March 22 Budget documents, please click here.Read more by clicking on the download button.http://www.fmc-law.com/Publications/0611_Focus_On_Tax_Federal_Budget_2011.aspxMon, 06 Jun 2011 06:00:00 GMThttp://www.fmc-law.com/Publications/0611_Focus_On_Tax_Federal_Budget_2011.aspx