A travel companion for anyone who wants to discover or rediscover various aspects of international taxation, Introduction to International Tax in Canada is intended not only for all tax specialists who wish to update their knowledge but graduate students in taxation as well.
Unique to Thomson Reuters, this publication discusses the fundamental notions of international taxation, the matter of foreign affiliates, with chapters concerning foreign accrual property income, shareholders’ dividend and reclassification of certain income concepts as well as tax issues pertaining to some hot topics such as E-Commerce and BEPS.
The book guides professionals and students through the concepts of transfer pricing with respect to OECD (Organization for economic co-operation and development), in relation with both Canada and the United States’ regulations. Finally, in addition to the theoretical section, the reader has access to valuable exercises at the end of each chapter, which makes this book a complete tool and a solid reference in international taxation for both students and practitioners.
The 2018 English edition of the book "Introduction to International Tax in Canada" includes 3 new chapters in addition to the usual improvements and updates. In the new chapter 5 (Tax Law Interpretation), Allison Christians introduces the basic concepts and purpose behind interpretation, as well as the methods and arguments of interpretation. In chapter 6 (Interpretation of Canadian Tax Treaties), Allison Christians explores the different applicable treaties and how they are subject to caselaw, doctrine and their overall impact on tax law. Finally, in chapter 13 (Cash Pooling), Sébastien Rheault, Julie Michaud and Jing Yu Wang discuss cash pooling agreements, which allow corporations to gather their “cash” in one unique point. While this may be interesting from an operational or financial standpoint, this may pose some tax challenges which are addressed in this chapter.