International Tax Law in Canada: Taxation of Cross-Border Income in the Canadian Context

International Tax Law in Canada: Taxation of Cross-Border Income in the Canadian Context provides a comprehensive explanation of international tax law in the Canadian context, considering domestic rules, treaty provisions, judicial decisions and administrative guidance that governs the taxation of non-residents on income from Canadian sources and the taxation of Canadian residents on income from foreign sources.

Part I provides an introduction to the sources and structure of international tax law, including foundational rules defining a person’s residence for tax purposes, and anti-avoidance rules addressing tax treaty shopping, commercial and financial arrangements among associated enterprises, and base erosion and profit shifting though interest and financing expenses and hybrid mismatch arrangements.

Part II examines domestic and treaty provisions, judicial decisions and administrative guidance governing the taxation of non-resident persons on Canadian source income, considering the taxation of non-residents on income from employment in Canada, income from a business carried on in Canada, taxable capital gains from the disposition of taxable Canadian property, income from property in Canada, and income from other Canadian sources, as well as special rules for income derived from personal activities in Canada by entertainers and sportspersons.

Part III examines domestic and treaty provisions, judicial decisions and administrative guidance governing the taxation of Canadian residents on foreign source income, considering foreign tax credits and deductions that reduce or eliminate double taxation of foreign source income, the taxation of Canadian residents on income derived by and from foreign affiliates, and the taxation of non-resident trusts, income from offshore investment fund property and income from investments in non-resident commercial trusts.

Part IV reviews OECD/G20 Pillar Two proposal for a global minimum tax and examines the Global Anti-Base Erosion (GloBE) Model Rules, Commentary and Administrative Guidance, on which domestic legislation implementing the global minimum tax is based.

Who Should Read This Book

• Tax law practitioners for practical advice on international tax issues
• Wills and estates lawyers who may want to refer to international tax decisions
• Tax law professors for use as text for tax law courses
• Law, accounting and business students as a core text for tax law courses
• Law libraries for reference and patrons to read