Canadian Taxation of Non-Residents, 5th Edition

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Canadian Taxation of Non-Residents explores the inbound international tax issues of non-residents in Canada who derive income from Canadian sources

The fifth edition of this highly successful book explores the inbound international tax issues of non-residents in Canada who derive income from Canadian sources. Tax issues are analyzed in terms of the application of the relevant sections of the Income Tax Act and provincial statutes, the application of the Canada-U.S. Income Tax Convention, and the application of Canada's other tax treaties.

This edition has been updated with new case law and recent changes to legislation and CRA pronouncements for practitioners who deal with the subject matter and need to stay current on the issues in order to properly advise their clients.

Other significant updates include:

  • The changes to the definition of "taxable Canadian property" and the resulting implications for non-residents who invest in Canadian property or realize capital gains from Canadian sources
  • Major changes in the "thin capitalization" rules that apply to the deductibility of interest paid to non-residents, including expansion of the rules to cover interest paid by trusts, not just corporations
  • Changes to the tax rules that apply to Canadian trusts or estates that earn certain types of income ( "designated income") that pay such income to non-resident beneficiaries
  • Changes to the rules that apply to loans made by Canadian corporations to non-resident shareholders that may allow those loans to remain outstanding indefinitely without being taxed

Discussions and commentary on the above developments would be of interest to Canadian accounting and legal practitioners alike who act for individual or corporate non-resident clients. Corporations with U.S. employees working on short term assignments in Canada would also be interested in this area of taxation. Also, non-resident professional advisors, particularly in the U.S., who need a general reference guide to assess the Canadian tax implications of certain past or proposed transactions would also find the content useful.

About the Author

Michael I. Atlas, C.A., C.P.A., T.E.P. is a Chartered Professional Accountant who practices as an independent tax consultant, in connection with a wide-range of domestic and international tax issues, in Toronto. Prior to forming his own practice in 1991, he was the partner in charge of the tax group of one of the 20 largest accounting firms in Canada.

His consulting practice places particular emphasis on international and cross-border tax planning matters.

He has been a frequent speaker on tax matters for many professional and business organizations, including the Canadian Tax Foundation, the Society of Trust and Estate Practitioners, the Institute of Chartered Accountants of Ontario, the Canadian Bar Association, and the Canadian Real Estate Association.

He is also the author of many articles that have appeared in Wolters Kluwer's Tax Topics, as well as many other publications.

He is a graduate of the University of Texas at Austin and a member of the Institute of Chartered Accountants of Ontario. In addition, he is a U.S. Certified Public Accountant (Illinois).

Michael Atlas may be reached by e-mail at matlas@TaxCA.com.

His Canadian International Tax Blog can be accessed at www.TaxCA.com/blog.

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