지원사업
학술연구/단체지원/교육 등 연구자 활동을 지속하도록 DBpia가 지원하고 있어요.
커뮤니티
연구자들이 자신의 연구와 전문성을 널리 알리고, 새로운 협력의 기회를 만들 수 있는 네트워킹 공간이에요.
초록· 키워드
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Canada’s tax policy makers and tax administrators have nevertheless not been idle. The cycle of tax amendments and audit projects to respond to tax planning innovations by taxpayers and their advisors continues as it always has.
The legislative and administrative focus on international tax issues is due as much to the evolution of the Canadian economy and globalization (i.e., a general increase in cross-border transactions and relationships for both individuals and businesses) as to specific revenue raising initiatives spurred by the recession. And, while there has been an uptick in government initiatives dealing with international tax in the past five years, this is properly seen as part of a trend that began in the late 1990’s.
This article addresses some of the more significant elements of this recent international focus. The topics addressed include Tightening of Canada’s thin capitalization rule, Introduction of foreign affiliate dumping rules, Transfer pricing developments and cases, Anti-hybrid rules in the Canada ? U.S. Income Tax Convention, Services permanent establishment rule in the Canada ? U.S. Income Tax Convention, Treaty shopping tax litigation cases, Limitation on benefits article in the Canada ? U.S. Income Tax Convention, Increases to the international tax audit capacity of the CRA, Increased reporting requirements for foreign property holdings and international transactions.
The foregoing discussion of Canada’s focus on international tax in legislation, treaties, tax audits and tax litigation demonstrates the importance of international tax in the Canadian tax system. The legislative rules governing the international affairs of Canadian residents and the Canadian affairs of non-residents are growing more extensive and more complex. Canada’s double tax conventions are increasingly addressing treaty shopping in one way or another. Finally, CRA’s attention and pursuit of international tax issues in tax audits and tax litigation is on the rise.
The legislative and administrative focus on international tax issues is due as much to the evolution of the Canadian economy and globalization (i.e., a general increase in cross-border transactions and relationships for both individuals and businesses) as to specific revenue raising initiatives spurred by the recession. And, while there has been an uptick in government initiatives dealing with international tax in the past five years, this is properly seen as part of a trend that began in the late 1990’s.
This article addresses some of the more significant elements of this recent international focus. The topics addressed include Tightening of Canada’s thin capitalization rule, Introduction of foreign affiliate dumping rules, Transfer pricing developments and cases, Anti-hybrid rules in the Canada ? U.S. Income Tax Convention, Services permanent establishment rule in the Canada ? U.S. Income Tax Convention, Treaty shopping tax litigation cases, Limitation on benefits article in the Canada ? U.S. Income Tax Convention, Increases to the international tax audit capacity of the CRA, Increased reporting requirements for foreign property holdings and international transactions.
The foregoing discussion of Canada’s focus on international tax in legislation, treaties, tax audits and tax litigation demonstrates the importance of international tax in the Canadian tax system. The legislative rules governing the international affairs of Canadian residents and the Canadian affairs of non-residents are growing more extensive and more complex. Canada’s double tax conventions are increasingly addressing treaty shopping in one way or another. Finally, CRA’s attention and pursuit of international tax issues in tax audits and tax litigation is on the rise.
목차
Ⅰ. Introduction
Ⅱ. Fundamentals of Canadian Taxation
Ⅲ. Declining Tax Rates
Ⅳ. Recent International Tax Changes to the Income Tax Act (Canada)
Ⅴ. Transfer Pricing
Ⅵ. International Tax Treaties
Ⅶ. Tax Information Exchange Agreements
Ⅷ. International Tax Audits and Compliance
Ⅸ. Conclusion
〈Reference〉
〈Abstract〉
참고문헌 (11)
참고문헌 신청
1. [보고서] - Advisory Panel on Canada’s System of International Taxation / 2008 / Final Report:Enhancing Canada’s International Tax Advantage
2. [학술대회논문] - Andrew W. Dunn / 2010 / Canada Revenue Agency Round Table / Report of Proceedings of Sixty-First Tax Conference, 2009 Tax Conference
3. [기타자료] - Canada Revenue Agency / 2010 / Income Tax - Technical News No. 42 / May 31
4. [보고서] - Canada, Department of Finance / 2007 / Legislative Proposals and Explanatory Notes to Implement Remaining Budget 2007 Tax Measures
5. [학술대회논문] - Corrado Cardarelli / 2008 / The Fifth Protocol to the Canada-US Income Tax Convention: Provisions Relating to Hybrid Entities, Service Businesses and Pension Plans / 2008 CTF Conference report
2. [학술대회논문] - Andrew W. Dunn / 2010 / Canada Revenue Agency Round Table / Report of Proceedings of Sixty-First Tax Conference, 2009 Tax Conference
3. [기타자료] - Canada Revenue Agency / 2010 / Income Tax - Technical News No. 42 / May 31
4. [보고서] - Canada, Department of Finance / 2007 / Legislative Proposals and Explanatory Notes to Implement Remaining Budget 2007 Tax Measures
5. [학술대회논문] - Corrado Cardarelli / 2008 / The Fifth Protocol to the Canada-US Income Tax Convention: Provisions Relating to Hybrid Entities, Service Businesses and Pension Plans / 2008 CTF Conference report
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UCI(KEPA) : I410-ECN-0101-2014-320-002876568