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Halsbury's Laws of Canada – Income Tax (International) (2019 Reissue)

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.
by Vern Krishna (Author)
Publisher: LexisNexis Canada
Publication Language: English
Book
$320.00
Quantity

Hardcover | 680 pages

In Stock
Published: November 26, 2019
ISBN/ISSN: 9780433502500
Publisher: LexisNexis Canada

Product description

Begin updating your law library today!

$135* per volume (ISBN: 9780433454946) OR purchase individual volumes at $320 each.

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*Per volume with commitment to purchase the entire 72-volume set.

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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
 

Featured Authors

Vern Krishna

Vern Krishna

Vern Krishna, C.M., Q.C., B.Comm., MBA, LL.B., LL.M., DCL, LL.D. (hc), FRSC, LSM, FCPA, is Counsel with Tax Chambers LLP, and Canada’s leading authority on income taxation in Canada. A Professor of Law at the University of Ottawa, Mr. Krishna graduated from the University of Manchester (U.K.) with a B. Comm.; the University of Alberta with an MBA 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 Ontario Bar (1983), a Fellow of the Royal Society of Canada, a Fellow of the Chartered Professional 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, including the Halsbury’s Laws of Canada titles Income Tax (International) and Income Tax (Corporate). He is listed in Who's Who Canada, and acts as counsel in tax litigation, international tax planning, and wealth management with Tax Chambers LLP (Toronto).

View all books by Vern Krishna (10)

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
 

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