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International Taxation in Canada - Principles and Practices, 3rd Edition

This edition continues the journey of assisting the reader to understand Canada's international tax regime. The authors strive to do so as comprehensively as possible, without overwhelming their audience with the massive scope and complexity of the topic.
Publication Language: English
In Stock
ISBN/ISSN: 9780433475675

Product details

>The Key to Understanding a Complex Subject
The first comprehensive book on Canadian international tax law, International Taxation in Canada – Principles and Practices was originally published in 2006. Now in its third edition, it has become the leading book on this topic in Canada and is the most widely-adopted book for classroom usage at Canadian law schools. A unique and resourceful tool, it provides an understanding of the underlying policy governing international tax rules as well as how foreign tax laws interact with Canadian laws.

Key Features and Benefits
  • Emphasizes the policy aspects associated with international tax law - offering a deep understanding of the significance of the technical tax rules
  • Offers a unique way to understand complex tax rules by focusing on the fundamental structure of the international system (for example: the distinction between the tax treatment of passive and active income)
  • Tables and charts help highlight the key themes and building blocks of the international tax system - providing easy reference to the more detailed discussions in the text of a particular regime
  • Examples and illustrations of the tax treatment of different cross-border transactions and arrangements
  • Easy to understand, with explanations of difficult technical rules, including an overview at the beginning of each section
  • Topical and analytical - learn from the experts as the authors share their understanding and analysis
  • Problems and case studies discussed in fully exploring the more recent developments of international tax law in Canada

New In This Edition
  • Now offers an expanded and deeper analysis of Canada's international tax regime
  • Updates relevant tax laws, including the most recent legislative approaches to the taxation of foreign affiliates (and the tie-in to tax information exchange agreements); and non-resident trusts
  • Discusses recent case law, including: Garron Family Trust, GlaxoSmithKline, Copthorne Holdings, Lehigh Cement, Velcro Industries, Alberta Printed Circuits, and McKesson Canada
  • Describes proposed anti-tax treaty shopping rules for Canada as well as related Organisation for Economic Cooperation and Development (OECD) efforts
  • Discusses Canadian international tax reform efforts within the OECD Base Erosion and Profit Shifting (BEPS) project that strives to inhibit aggressive international tax avoidance
  • Provides analysis of the ongoing legal and policy changes surrounding cross-border tax information exchange

Who Should Read This Book?
  • Students of law, accounting and business
  • Tax law professors in Canada, United States and Europe
  • Tax lawyers and practitioners
  • Law firms
  • Judges
  • Policy makers

Featured authors

Table of contents

Chapter 1: Introduction
Part I - Fundamentals of International Taxation in Canada
Chapter 2: System Design
Chapter 3: Tax Treaties
Chapter 4: Tax Jurisdiction
Chapter 5: Transfer Pricing
Part II - Inbound Taxation
Chapter 6: Overview: Taxation of Nonresidents Earning Income from Canada
Chapter 7: Non-residents "Employed in Canada"
Chapter 8: Non-residents "Carrying on Business in Canada"
Chapter 9: Non-residents Disposing "Taxable Canadian Property"
Chapter 10: Non-residents Receiving Payments from Canada
Part III - Outbound Taxation
Chapter 11: Overview: Taxation of Residents Earning Income from Foreign Countries
Chapter 12: Foreign Tax Credit
Chapter 13: Non-resident Trusts
Chapter 14: Foreign Affiliates
Chapter 15: Foreign Investment Intermediaries
Part IV - Tax Avoidance and Administration
Chapter 16: Tax Planning, Tax Havens and the Compatibility of Tax Systems
Chapter 17: Anti-Avoidance Rules
Chapter 18: Tax Administration and Dispute Resolution
Part V - International Trade
Chapter 19: International Trade and Tax
Appendix: Convention Between Canada and the United States of America With Respect to Taxes on Income and on Capital