U.S.-Canada Corporate Tax Challenges With Surge in Cross Border Deals, More Aggressive Enforcement, FATCA Effective

Description

Over the past few years, developed countries have adopted increasingly aggressive policies to combat tax evasion and tax planning perceived as abusive or inappropriate. Witness, in the U.S., the rapidly approaching FATCA compliance deadline and, internationally, the OECD’s Base Erosion and Profit Shifting or “BEPS” initiative.

As part of this broader trend, Canada has heightened focus on suspect tax practices, both in enforcing existing tax laws and in adopting new or amending existing laws targeted to potentially abusive tax planning or evasion.

The focus on U.S. company taxation continues with the phasing in of important compliance and tax planning changes required by the U.S.-Canada Income Tax Convention (Treaty)'s Fifth Protocol. Recent developments involving Canadian tax policy toward American businesses also command the attention of businesses operating on both sides of the border.

Canada's most high-visibility actions include entering into a new intergovernmental agreement with the United States, increased Canada Revenue Agency (CRA) focus on transfer pricing, significant new court rulings dealing with transfer pricing disputes, significant changes to Canada’s thin capitalization rules, and proposed new anti-treaty shopping initiatives. Tax professionals for U.S. firms doing business in Canada need to stay up to date.

Listen as our panel of experienced tax advisors offers analysis of and insights for tax professionals and attorneys into the most recent, relevant developments in corporate tax in Canada that affect U.S. companies.