Halsbury's Laws of Canada – Income Tax (International) (2015 Reissue)

Publisher: LexisNexis Canada
Format::  Book, 2
ISBN:: 9780433487265


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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 affiliatesPart I tax liability of non-residentsJurisdiction of international tax treatiesDouble taxation

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


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

Vern Krishna, CM., QC, B.Comm., MBA, LL.B, LL.M, DCL, LL.D (Hon), FRSC, LSM, FCPA (FCGA), is one of the leading authorities on income taxation in Canada. A Professor of Law at the University of Ottawa's Faculty of Law, and Of Counsel, TaxChambers LLP (Toronto), Mr. Krishna graduated from the University of Manchester (U.K.) with a B. Comm.; the University of Alberta with an M.B.A. and an LL.B.; Harvard Law School with an LL.M.; and Cambridge University (U.K.) with a Diploma in Comparative Law. He is a Member of the Order of Canada, a recipient of the Queen's Diamond Jubilee Medal, a former Treasurer of the Law Society of Upper Canada (2001–2003), Fellow of the Royal Society, and Fellow of the Chartered Professional Accountants. He is the author of numerous books on domestic and international taxation, including the Halsbury's Laws of Canada titles, Income Tax (General) and Income Tax (Corporate). He is listed in Who's Who Canada and in Best Lawyers in Canada. Please refer to his personal website for updates: www.vernkrishna.com

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