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International tax alert archive

International tax alert is published as issues develop.


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


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


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


August 25, 2011: New foreign affiliate proposals on distributions, reorganizations and other transactions
August 22, 2011: Finance introduces new rules on repatriation from foreign affiliates, including loans of taxable surplus
June 2, 2011: Tax Information Exchange Agreements Ratified with Bermuda and the Cayman Islands
April 20, 2011: Glitch will delay ratification of many Canadian tax information exchange agreements


February 17, 2010: New CRA positions on hybrid entity provisions of the Canada-US treaty




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