Lexis Nexis International Taxation in Canada, 5th Edition
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Détails des produits
The first comprehensive book on Canadian international tax law, International Taxation in Canada was originally published in 2006. Now in its fifth edition, it has become the leading book on this topic and widely-adopted book for classroom usage in Canada. It offers an insightful overview of Canadian international taxation, with an eye to its organizing paradigms, underlying logic, technical design and practical implications. Combining over 60 years of experience in international tax law, the authors build on the success of previous editions by making the book more accessible to students and practitioners.
Features of This Book
- Synthesizes and explains Canadian international tax law as a system with its own internal logic, paradigm, principles and policy orientations
- Demystifies the complex tax rules, using accessible language and easy-to-follow examples
- Encourages readers to build on what they already know about basic income tax by showing how the international tax rules are a natural outgrowth of the basic rules
- "Humanizes” the rules by explaining why drafters chose them as a means of achieving important, and often conflicting policy objectives
- Focuses on the “real” law that affects Canadian taxpayers by covering basic rules as well as some highly sophisticated international anti-avoidance rules, including the Global Minimum Tax
- Strives to be a ready starting point for students and a “sanity check” and general reference for practitioners
What’s New in This Edition
- Two brand-new chapters covering:
- Taxation of foreign-controlled Canadian corporations (chapter 11)
- International tax reforms, including BEPS 1.0 and BEPS 2.0 (e.g., Pillar 1 and Pillar 2) and the future of Canadian income tax law (chapter 17)
- A new chapter on tax treaties was created by updating materials in former chapter 2
- The taxation of foreign affiliates is separated into two chapters, featuring FAPI in chapter 15 and dividends in chapter 16
- Many existing chapters have been significantly rewritten
- More context and explanation of historical evolution of key international tax rules and principles, as well as the major influences and constraints on Canadian International law
Who Should Have This Book
- Tax lawyers and practitioners – as a refresher and general reference for the basic rules
- Tax professors – for use as text for international tax courses
- Students of law, accounting and business – as a core text for tax law courses
- Law libraries – for reference and patrons to read
Table des matières
Chapter 1: Introduction
PART I – GENERAL PARADIGM AND PRINCIPLES
Chapter 2: The Canadian International Tax System
Chapter 3: Tax Treaties
Chapter 4: Tax Jurisdiction
Chapter 5: Transfer Pricing
PART II – INBOUND TAXATION
Chapter 6: Legislative Schemes and Rationale
Chapter 7: Employed in Canada
Chapter 8: “Carrying on Business in Canada”
Chapter 9: “Taxable Canadian Property”
Chapter 10: Taxes on Income from Passive Investments and Branch Profits
Chapter 11: Foreign Owned Canadian Corporations
PART III – OUTBOUND TAXATION
Chapter 12: Legislative Schemes and Rationale
Chapter 13: Foreign Tax Credit
Chapter 14: Foreign Trusts and Investment Funds
Chapter 15: Controlled Foreign Affiliates and Passive Income
Chapter 16: Dividends from Foreign Affiliates
PART IV – FUTURE CHANGES
Chapter 17: International Tax Reforms
PART V – INTERNATIONAL TRADE
Chapter 18: International Trade and Tax
Table of Cases
Index
