Halsbury's Laws of Canada - Income Tax (International)

Halsbury's Laws of Canada - Income Tax (International)

Canada imposes taxes based on taxpayer residence and on the source of income, and the rules relating to this international taxation are complex. This title presents a straightforward and lucid explanation of those rules, and how they are applied by the taxing authorities.

Fournisseur LexisNexis Canada
Pays: Canada
Format Hardcover Book
Langue de publication: English
ISBN 9780433459866
Date de publication: 2010-12-31

				Prix: 280,00 $

Quantité :

Begin updating your law library today!

$135* per volume (ISBN: 9780433454946) OR purchase individual volumes at $280 each.

For more information or to place an order please contact us.

*Per volume with commitment to purchase the entire 77-volume set.

------------------------------------------------------------------------------------

It has been often said that nothing is certain but death and taxes, and it's no surprise that no exceptions are made for extra-jurisdictional revenue. Canada imposes taxes based on taxpayer residence and on the source of income, and the rules relating to this international taxation are complex. This title presents a straightforward and lucid explanation of those rules, and how they are applied by the taxing authorities. Topics covered in this essential reference include:

Foreign affiliates

Equity percentage
Anti-avoidance rules

Part I tax liability of non-residents

Employment income
Carrying on business in Canada
Capital gains
Treaty obligations

Jurisdiction of international tax treaties

Law of the forum
Scope of treaties
Jurisdiction to impose taxes

Double taxation

Resident and source taxation
Corporations
Relief

Special Features

Enhanced contents
- A general table of contents to the level of chapter headings
- A detailed table of contents to the level of clause headings
- Detailed sectional contents set out within the commentary for each chapter and section
References and abbreviations - An alphabetical listing of special references and abbreviations used in the volume, with an explanation of their meaning
Selected secondary sources -Setting out selected texts, articles, and other secondary sources pertaining to the subject that the reader may find to be relevant and helpful
Glossary of definitions -Identifying words and phrases defined in personal property security legislation, and providing the text of the definition in each jurisdiction for easy reference. A valuable quick reference in a field marked by a wide variety of statutes promulgated across many jurisdictions

Plus:

Table of Cases
Table of Statutes and Statutory Instruments
List of Related Titles
Index

I. Foreign Source Income
1. General
2. Taxation of Profits
3. Foreign Affiliates
4. Business Income
5. Foreign Accrual Property Income
6. Holding Companies
7. Sale of Foreign Investments
8. Anti-Avoidance Rule
II. Non-Residents
1. Overview
2. Part I Tax Liability
3. Withholding Tax
4. Forms of Business
5. Corporate Finance
III. Offshore Trusts
1. Overview
2. Parties
3. Location
4. Deemed Residence
5. Asset Protection
6. Taxation of Passive Income
7. Administration
IV. International Tax Treaties
1. Overview
2. Model Treaties
3. Interpretation
4. Jurisdiction
5. Double Taxation
6. Tax Sparing
7. Business Income
8. Other Forms of Income
9. Capital Gains
10. Dividends
11. Interest
12. Royalties
13. Affiliated Corporations
14. Independent and Dependent Personal Services
15. Individuals
16. Non-Discrimination Clauses
17. Governmental Services
18. Withholding Taxes
19. Capital
20. Treaty Shopping
21. Beneficial Ownership
22. Treaty Rules and Procedures

Vern Krishna, C.M., Q.C., F.R.S.C., LL.M., D.C.L., LL.D, (Hons.)

Vern Krishna, C.M., Q.C., LL.D., F.C.G.A., is Tax Counsel with Borden Ladner Gervais LLP and one of Canada’s leading authorities on income taxation in Canada. A Professor of Law at the University of Ottawa’s Faculty of Law, Mr. Krishna graduated from the University of Manchester (U.K.) with a B. Comm.; the University of Alberta with a M.B.A. and a LL.B.; Harvard Law School with a LL.M.; and Cambridge University (U.K.) with a Diploma in Comparative Law. He is a Member of the Ontario Bar (1983), a Fellow of the Royal Society of Canada, a Fellow of the Certified General Accountants of Canada, Queen’s Counsel, and a member of the Order of Canada. Mr. Krishna was the Treasurer of the Law Society of Upper Canada (2001–2003) and is the Author of numerous books on domestic and international taxation. He acts as counsel in tax litigation, international tax planning, and wealth management with Borden Ladner Gervais.

Canada

Recherche par juridiction

Recherche par domaine de pratique

Recherche par rôle

Recherche par produit

Formulaire de demande d'un exemplaire de consultation

Ouvrages en français