Canada Tax News

Fifth protocol to treaty between Canada and US – details

4 November 2007

Treaty between Canada and Columbia – negotiations

1 October 2007

OECD releases revised draft of Part IV (Insurance) of the Report on Attribution of Profits to Permanent Establishments

2 September 2007

Treaty between Canada and Luxembourg – Canadian Federal Court of Appeal upholds Tax Court decision on non-applicability of general anti-avoidance rule to sale of shares

29 July 2007

Implementation of key Budget 2007 measures

2 July 2007

Anti-tax-haven initiative

18 June 2007

Treaty between Canada and Greece – negotiations

18 June 2007

Discussion draft on application and interpretation of non-discrimination article of OECD Model – details

18 June 2007

Treaty between Mexico and Canada ratified

28 May 2007

Revised Commentary on Article 7 of OECD Model released

28 May 2007

Budget 2007 highlights

28 April 2007

Budget 2006 tax measures fully implemented

28 April 2007

Final Report on Improving the Resolution of Tax Treaty Disputes

24 March 2007

Treaty between Canada and Korea (Rep.) enters into force

24 February 2007

Treaty between Finland and Canada enters into force

24 February 2007

Report on Attribution of Profits to PEs released

24 February 2007

Treaties with the United States and Canada considered

15 January 2007

Finland ratifies treaty between Finland and Canada

15 January 2007

Treaty between Canada and Malaysia – negotiations to start

17 December 2006

Treaty between Mexico and Canada – details

12 November 2006

Amendment to treaty between China (People's Rep.) and Canada

14 October 2006

Treaty between Korea (Rep.) and Canada signed

14 October 2006

Proposed legislation to eliminate double taxation of dividends paid by large Canadian corporations to Canadian individual shareholders

12 September 2006

Treaty between Finland and Canada – details

12 September 2006

Budget 2006 highlights

14 June 2006

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.

19 February 2006

French Guideline on treaty treatment of Canadian mutual funds in securities published

19 February 2006

Tax Court finds anti-avoidance rules not violated

6 December 2005

Tax Court of Canada applies tie-breaker rules in CanadaKorea (Rep.) tax treaty to determine residence status

16 October 2005

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.

16 October 2005