Lexis Nexis 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:
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
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
