International Taxation in Canada - Principles and Practices, 4th 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.
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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 fourth 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
- Updating and unpacking recent legislative changes (such as the back-to-back rules in Part XIII) and recent cases such as Lehigh Cement Limited
- New chapters on global tax reporting, country-by-country reporting, and international tax dispute resolution
- To help the reader digest complex tax issues, the new edition situates international tax rules in the broader context of an international tax paradigm and the OECD/ G20 Base Erosion and Profit Shifting (BEPS) Project
- Multiple chapters have been significantly revised to reflect major changes in Canada and internationally
Who Should Read This Book?
- Students of law, accounting and business - as a core text for tax law courses
- Tax law professors - for use as text for tax law courses
- Tax lawyers and practitioners - for practical advice on international tax issues
- Law libraries - for refeence and patrons to read
Table of contents
Chapter 1: International Tax Paradigm
Chapter 2: Canadian International Taxation: System Design
Chapter 3: Tax
Chapter 4: Transfer Pricing
Chapter 5: Overview: Taxation of Non-Residents Earning Income from Canada
Chapter 6: “Employed in Canada”
Chapter 7: : “Carrying on a Business in Canada”
Chapter 8: Disposing “Taxable Canadian Property”
Chapter 9: “Receiving Payments from Canada”
Chapter 10: Overview: Taxation of Residents Earning Income from Foreign Countries
Chapter 11: Foreign Tax Credit
Chapter 12: Non-resident Trusts
Chapter 13: Foreign Affiliates
Chapter 14: Foreign Investment Intermediaries
Chapter 15: Tax Planning and Anti-Avoidance Rules
Chapter 16: Tax Reporting and Global Tax Information Exchange
Chapter 17: Cross-Border Tax Cooperation and Dispute Resolution
Chapter 18: International Trade and Tax
Chapter 19: Appendix - Convention Between Canada and the United States of America With Respect to Taxes on Income and on Capital