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

Description

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

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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

Table of Contents

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

Author/Contributor

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.

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