|
| |
Articles
1-100 out of 100 article(s)
| Title |
Author |
Type |
Date |
Words |
| Adverse Canada-U.S. Tax Treaty Hybrid Entity Rules Coming Into Effect January 1, 2010. |
|
|
Dec 2, 2009 |
3026 |
| Canada Revenue Agency Interprets Anti-Hybrid Rule. |
|
|
Dec 1, 2009 |
2087 |
| CRA Releases Treaty Guidelines For US-Owned UlCs But Planning Is Required. |
|
|
Dec 1, 2009 |
1554 |
| CRA Provides Its Latest Views On Planning For Canada-U.S. Tax Treaty Changes And Other Issues. |
|
|
Nov 26, 2009 |
1164 |
| Special Purpose Companies Holding Investments In China May Not Be Protected By Tax Treaties. |
Cao, Fuli |
|
Nov 12, 2009 |
924 |
| Details Of The New Double Tax Treaty Between Cyprus And The Czech Republic. |
|
|
Nov 3, 2009 |
617 |
| Colombia's Recent Tax Developments*. |
Rodriguez, Adrian |
|
Nov 3, 2009 |
1543 |
| Significant Changes To The US-France Tax Treaty Protocol. |
|
|
Oct 28, 2009 |
1688 |
| Spain keen on tax treaty. |
|
|
Oct 11, 2009 |
393 |
| Planning For The Entry Into Force Of Treaty Changes Affecting Hybrid Entities On January 1, 2010. |
|
|
Oct 8, 2009 |
2955 |
| Canadian 'anti-hybrid' rules: review agreements by January 2010. |
Lysenko, Jonathan |
|
Oct 1, 2009 |
435 |
| Tax treaty with Mexico. |
|
|
Oct 1, 2009 |
146 |
| 12TH BVI tax exchange accord. |
|
|
Oct 1, 2009 |
108 |
| Colombian Tax Flash - September 2009. |
|
|
Sep 29, 2009 |
1833 |
| Canada Signs Its First Tax Information Exchange Agreement. |
|
|
Sep 25, 2009 |
1079 |
| The New U.S.-Italy Treaty: A U.S. Perspective. |
|
|
Sep 23, 2009 |
9274 |
| Time To Restructure: Canadian ULC Structures Adversely Affected By Amended Canada-US Tax Treaty. |
|
|
Sep 20, 2009 |
324 |
| Tougher Rules For Claim For Tax Treaty Benefits In China. |
|
|
Sep 17, 2009 |
1577 |
| UK-Swiss treaty on tax transparency. |
|
|
Sep 8, 2009 |
111 |
| Reminder: Anti-Hybrid Rules In Canada-U.S. Income Tax Treaty To Take Effect In 2010. |
|
|
Sep 2, 2009 |
292 |
| Treaty Shopping: An Update. |
McCay, Patrick |
Law overview |
Sep 1, 2009 |
4957 |
| Certain Taxation Issues Relating To Life Insurance Settlements. |
Gallagher, Thomas |
|
Aug 31, 2009 |
956 |
| India will look into the Swiss banks rejection to disclose details: Mukherjee. |
|
|
Aug 24, 2009 |
273 |
| Island strikes DTA with Baltic State. |
|
Brief article |
Aug 17, 2009 |
260 |
| Time to Restructure: Canadian ULC Structures Adversely Affected By Amended Canada-US Tax Treaty. |
McCay, Patrick |
Brief article |
Aug 3, 2009 |
315 |
| Bahrain extends tax information network. |
|
Brief article |
Jul 23, 2009 |
260 |
| The Changing Environment. |
|
|
Jul 22, 2009 |
4407 |
| International Double Taxation In Portugal. |
|
|
Jul 16, 2009 |
962 |
| Time For A Change: Toward A New Korea-U.S. Income Tax Treaty. |
Lee, Lucy |
|
Jul 14, 2009 |
7846 |
| Cyprus-Russia: The Amendments To The Double Tax Treaty. |
Tillirou, Phani |
|
Jun 30, 2009 |
967 |
| The Ultimate Experience Of Cyprus c. |
Stylianou, Sophie |
Law overview |
Jun 30, 2009 |
2534 |
| International Trusts And Double Tax Treaty Provisions. |
Stylianou, Sophie |
|
Jun 29, 2009 |
774 |
| The Belgian Connection. |
|
|
Jun 24, 2009 |
634 |
| United States: Swiss strike tax deal with US. |
|
|
Jun 20, 2009 |
265 |
| Tax treaty net basis elections. |
Lan, David; Karges, Martin |
|
May 1, 2009 |
1667 |
| U.S. - Brazil CEO Forum Offers Support for Senate Resolution Urging Creation of Bilateral Tax Treaty. |
|
|
Mar 13, 2009 |
532 |
| Appeal Court Finds Taxpayer to be "Beneficial Owner" Under Tax Treaty. |
|
Case overview |
Mar 12, 2009 |
1348 |
| Double Taxation Treaties Signed By Colombia. |
Abella, Maria Del Pilar |
|
Feb 17, 2009 |
728 |
| Requirements for the creation of permanent establishment in Germany. |
Urbahns, Rudiger |
|
Feb 1, 2009 |
669 |
| Protocol Amending The Canada-US Tax Treaty Enters Into Force. |
Charette, Jules |
|
Jan 28, 2009 |
1020 |
| Salans Kyiv Tax Newsletter. |
|
|
Jan 6, 2009 |
1165 |
| Changing The Borders - Report Of Canadian Advisory Panel On International Taxation. |
|
|
Dec 29, 2008 |
4497 |
| Fifth Protocol to Canada - U.S. tax treaty enters into force. |
|
Brief article |
Dec 25, 2008 |
252 |
| Protocol To Canada-U.S. Tax Treaty Enters Into Force. |
|
|
Dec 17, 2008 |
343 |
| Fifth Protocol To The Canada-U.S. Income Tax Convention Enters Into Force. |
Steeves, Christopher |
|
Dec 16, 2008 |
712 |
| Trustees' Duties And Liabilities Under Mauritius Law. |
Bette-Bennett, James |
|
Dec 4, 2008 |
928 |
| UK and Libya sign double taxation convention. |
|
|
Nov 19, 2008 |
278 |
| Research and Markets: An Analysis of Mandatory Arbitration Procedures: Discover a New Tack for Resolving Double Taxation Disputes between Competent Authorities. |
|
|
Nov 19, 2008 |
218 |
| Selected provisions of the Fifth Protocol to the U.S.-Canada Income Tax Treaty. |
Carsalade, Rafael |
|
Nov 1, 2008 |
1635 |
| Limited Partnerships In Guernsey. |
Cayman, Grand |
|
Oct 17, 2008 |
4450 |
| Double taxation treaties (DTT). |
|
|
Oct 14, 2008 |
1383 |
| U.S. Senate Approves Protocol To Canada-U.S. Tax Treaty. |
|
|
Oct 14, 2008 |
830 |
| Double Taxation Treaties; After Spain And Chile, New Treaty With Switzerland. |
|
|
Oct 9, 2008 |
1800 |
| Government Bill For New CFC Legislation Issued. |
Juusela, Janne |
|
Sep 30, 2008 |
602 |
| Technical Explanation And U.S. Senate Hearing bring Canada-U.S. Treaty Protocol Closer To Ratification. |
Boidman, Nathan |
|
Sep 22, 2008 |
2860 |
| Clarification On The Protocol To Canada-U.S. Income Tax Convention. |
|
|
Sep 9, 2008 |
1488 |
| Permanent Establishment Under Canada-United States Tax Convention Part I - The Knights Of Columbus Decision. |
|
|
Sep 8, 2008 |
1340 |
| Changes Involved In The Termination Of The Franco-Danish Tax Treaty. |
Guionnet-Moalic, Claire |
|
Aug 28, 2008 |
781 |
| Canada-U.S. Protocol Moves Toward Ratification. |
|
|
Aug 18, 2008 |
345 |
| Treatment of loans to U.S. partners under the U.S.-Germany tax treaty. |
Urbahns, Rudiger |
|
Aug 1, 2008 |
623 |
| Technical Explanation Clarifies Protocol To Canada-U.S. Tax Treaty, Part One. |
|
Law overview |
Jul 24, 2008 |
5461 |
| Technical Explanation Clarifies Protocol To Canada-U.S. Tax Treaty, Part Two. |
|
|
Jul 24, 2008 |
5170 |
| Arbitration Provision Takes Aim At Competent Authority Deadlock. |
|
|
Jul 21, 2008 |
2025 |
| Technical Explanation To Protocol Offers Limited Guidance On Limitation On Benefits. |
|
|
Jul 21, 2008 |
5047 |
| An Introduction To The Technical Interpretation To The Fifth Protocol To The Canada-United States Income Tax Convention. |
|
|
Jul 18, 2008 |
1207 |
| Technical Explanation Offers No Relief For U.S. Residents With Interests In ULCs. |
|
|
Jul 18, 2008 |
2186 |
| Protocol Impacts Doing Business Cross-Border. |
|
|
Jul 18, 2008 |
2323 |
| Technical Explanation Clarifies Impact Of The Fifth Protocol On Employees. |
|
|
Jul 18, 2008 |
1362 |
| 378 Days To Victory: The Conduct Of A Ground-Breaking Tax Treaty Case, Knights Of Columbus v. R. |
|
Case overview |
Jul 9, 2008 |
1014 |
| Dutch Real Estate Investment Vehicles: Part 2. |
|
|
Jun 9, 2008 |
493 |
| Canadian Tax Authority Loses In Tax Court Case Concerning The "Beneficial Owner" Of Dividends Paid By A Canadian Subsidiary Of A Netherlands Holding Company. |
|
Case overview |
May 6, 2008 |
2360 |
| A coherent policy proposal for U.S. residence-based taxation of individuals. |
Blum, Cynthia; Singer, Paula N. |
|
May 1, 2008 |
19559 |
| IRS can't shake yardstick at tax treaty. |
Gilman, Jeffrey |
|
Apr 1, 2008 |
444 |
| Form 1042 information reporting requirements. |
Pasmanik, Philip T.; Verzi, Robert A. |
|
Apr 1, 2008 |
1916 |
| Commentary on the Canada-U.S. Tax Treaty's Fifth Protocol. |
Sardella, Joseph |
|
Mar 1, 2008 |
3103 |
| Canada-U.S. Tax Treaty Changes. |
|
|
Feb 14, 2008 |
893 |
| 5th April 2008 - Can the last person to leave the UK please turn out the lights ?? |
|
|
Feb 13, 2008 |
1680 |
| Pre-Budget Report. |
|
|
Feb 6, 2008 |
1403 |
| The Mauritius/India Double Tax Treaty (Without Tears). |
|
|
Jan 9, 2008 |
2632 |
| Tax treaty shopping and the GAAR: MIL (Investments) S.A. v. The Queen. |
Brown, Kimberly |
|
Jan 1, 2008 |
14353 |
| Fifth protocol: proposed amendments to United States-Canada Income Tax Treaty. |
Cornett, J. Michael |
|
Jan 1, 2008 |
3770 |
| TEI's comments on U.S.-Canada Tax Protocol: on September 21, 2007, the United States and Canada signed the Fifth Protocol (the "Protocol") to the U.S.-Canada Income Tax Treaty. The new Protocol will become effective upon ratification by the U.S. Senate and Canadian Parliament. The Protocol is also accompanied by two sets of diplomatic notes exchanged between the two countries. |
|
|
Jan 1, 2008 |
4034 |
| Canada/U.S. Sign New Tax Treaty. |
|
Brief article |
Sep 30, 2007 |
263 |
| Highlights Of The New Protocol To The Canada - U.S. Tax Treaty. |
Imerti, Vince |
|
Sep 28, 2007 |
1901 |
| U.S. Real Estate Fund Structures To Accomodate German Investors. |
Corey, Elizabeth |
|
Sep 3, 2007 |
2788 |
| Competently negotiating the U.S. competent authority process. |
Chung, Kerwin; McAlonan, Richard |
|
May 1, 2007 |
5725 |
| Canadian Tax @ Gowlings - September 2006. |
|
|
Oct 19, 2006 |
2081 |
| The 2003 United States - United Kingdom Income Tax Treaty- Kicking In. |
|
|
Sep 29, 2006 |
4525 |
| New U.S. reporting requirements for foreign multinationals. |
Boyd, Amy |
|
Jul 1, 2006 |
1109 |
| Taxing the global worker: three spheres of international social security coordination. |
Christians, Allison |
|
Jun 22, 2006 |
20528 |
| Three New Double Tax Treaties. |
|
|
Oct 7, 2005 |
1189 |
| Recent Income Tax Treaty Changes. |
|
|
Jul 1, 2005 |
1546 |
| The World Tax Advisor (Part One). |
|
|
May 5, 2005 |
7337 |
| Totalization agreements. |
Nazir, Sadia |
|
Sep 1, 2004 |
657 |
| Statement before Senate Foreign Relations Committee on Dutch and Barbados treaties: September 24, 2004. |
|
|
Sep 1, 2004 |
1300 |
| New Provisions For Exchange of Information. |
|
|
Aug 3, 2004 |
731 |
| Tei comments on clarification of PE definition: June 7, 2004. |
|
|
May 1, 2004 |
1351 |
| Mexico signed a new tax treaty with Australia to reduce double taxation and prevent tax evasion in both countries. |
|
Brief Article |
Apr 1, 2004 |
43 |
| Treaty-based excise tax exemptions. |
Safranek, Richard J. |
|
Mar 1, 2004 |
714 |
| Treaty bars attribution of capital to U.K. bank's U.S. branch. |
Fuller, Thomas D. |
|
Mar 1, 2004 |
730 |
|
