Halsbury's Laws of Canada – Income Tax (International) (2019 Reissue)
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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:
- 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
- Resident and source taxation
Table of contents
I. Foreign Source Income
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
2. Part I Tax Liability
3. Withholding Tax
4. Forms of Business
5. Corporate Finance
III. Offshore Trusts
4. Deemed Residence
5. Asset Protection
6. Taxation of Passive Income
IV. International Tax Treaties
2. Model Treaties
5. Double Taxation
6. Tax Sparing
7. Business Income
8. Other Forms of Income
9. Capital Gains
13. Affiliated Corporations
14. Independent and Dependent Personal Services
16. Non-Discrimination Clauses
17. Governmental Services
18. Withholding Taxes
20. Treaty Shopping
21. Beneficial Ownership
22. Treaty Rules and Procedures