Jul

In Walsh, 2011 TCC 341 the Tax Court deal with a fundamental issue: when preparatory activities undertaken by a taxpayer towards establishing a business become a business. In Walsh, the...

Jul

In Sruder, 2011 TCC 322, the Tax Court dismissed the taxpayer’s argument that the child support amounts could be deductible under Article 18(2)(d) of the Canada-Switzerland Tax Convention. In relevant...

Jun

In a recent tax ruling, the Canada Revenue Agency (“CRA”) allowed a taxpayer to claim as foreign tax credit a 10 percent income tax surcharge levied under the U.S. Internal...

May

Canada starts tax treaty negotiations with Hong Kong Canada just announced that it will soon commence tax treaty negotiations with Hong Kong.  There is indeed a tax treaty  (or tax...