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 2019 edition of the book Introduction to International Tax in Canada includes a new chapter in addition to many improvements and updates. In new chapter 20 (Taxation of an Offshore Investment Fund Property) Mathieu Gendron and Raphaël Zicat describe how section 94.1 remedy the avoidance or deferral of Canadian tax when a Canadian taxpayer holds an interest in a non-resident entity that is not a controlled foreign affiliate (CFA) and whose value is derived primarily from portfolio investments. The last section of Chapter 2 deals with changes that could be announced as early as 2020 by the OECD. The upheavals in international taxation have not ended. In addition, the last section of Chapter 15 deals with the new rules for tracking interests (subsections 95(8) to (12)). The authors are: Jean-Pierre Vidal, Julie Robson, Marie-Pierre Allard, Marwah Rizqy, Cindy Harvey, Florie Pellerin-Catellier, Candace M. Marriott, Annick Provencher, Sarah Baxter, Mathieu Gendron, Angelo Nikolakakis, Allison Christians, Chantal Jacquier, Nadia Rusak, Jonathan Charron, Sara Shearmur, Marie Blanchard, Marguerite Auclair, Sara-Michelle Marcotte-Génier, Jessica Di Maria, Raphaël Zicat, Judith Charbonneau Kaplan, Julie Michaud, Sébastien Rheault, Jing Yu Wang, Chantal Bélanger.