Background
Canada has a series of bilateral tax treaties. These have evolved over time to include various anti-avoidance, and anti-treaty shopping rules. These rules include limitation on benefits provisions and purpose tests. The treaty between Canada and Hong Kong had one of the broadest rules.
Many countries, including Canada and Hong Kong, are now signatories to the ...
In June 2022, Canada published a report concerning its tax gap.[1] A “tax gap” is the difference between (a) the amount of money a tax authority could collect, in theory, if everyone complied with the law; and (b) the amount in fact collected. Canada’s tax gap has remained stable for the period 2014 to 2018, at 9% of tax revenue.[2] This translates to between $20 billion ...
The enforcement by Canada Revenue Agency (“CRA”) of its super priority position for deemed trust liabilities has long been an issue of uncertainty for secured creditors. While the Excise Tax Act (the “ETA”) has carved out “prescribed security interests” from that super priority, the calculation of the funds that continue to rank in priority to a prescribe ...
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