James Hardie loses appeal against Australian tax authorities Panellists to share dispute resolution experiences German Supreme Court reverses squeeze-out compensation position Vodafone ruling date announced WTO rules EU in breach of international rules Tax disputes leaders vie for Americas Awards Cover Story Features Comment News People and Firms Tax relief Argentina Brazil Canada Chile Finland France Germany India Ireland Italy Japan Mexico Poland Portugal South Africa Thailand Ukraine US Inbound US Outbound Foreign Account Tax Compliance Act: A critical analysis Bearer bonds The Netherlands Budget and the patent box Asia 2009 Europe 2009 Americas 2009		International Briefings - Canada September 2010 Practical difficulties still exist when non-residents dispose of Canadian shares July 2010 Mandatory disclosure proposed for aggressive tax planning June 2010 Tax Court of Canada calls into question CRA's position on LLCs May 2010 Canada to provide welcome relief to foreign investors April 2010 Doubts cast on use of LLCs for investment purposes March 2010 More foreign affiliate tax rule changes introduced February 2010 Canadian guidance on anti-hybrid rules released December 2009 Unprecedented initiative by a province tackles aggressive tax planning November 2009 Residency of trusts - The Garron case October 2009 Restructuring in anticipation of new anti-hybrid rules September 2009 Draft treaty certification forms for non-residents July 2009 Amendment to Canadian definition of permanent establishment June 2009 Transfer pricing issues May 2009 Tax authorities lose appeal in beneficial ownership case April 2009 CRA interprets new service permanent establishment rules March 2009 Canadian tax authorities can require information stored on foreign servers February 2009 Recommendations for changes to system of international taxation released December 2008 Latest on Canada - US treaty amendments November 2008 Easing tax compliance for internationally-engaged Canadian businesses October 2008 Permanent establishments revisited September 2008 Canada-US tax treaty – Protocol update July 2008 Taxpayer wins treaty case on beneficial ownership June 2008 Two changes to the treatment of foreign exchange gains and losses May 2008 Canada-US treaty - limitation on benefits April 2008 Reduced compliance burden for cross-border investment in private equity March 2008 Relief for cross-border REITs announced February 2008 Year end enactments December 2007 Canada proposes income tax amendments November 2007 Fifth protocol to the Canada-US income tax convention signed October 2007 CRA attacks downstream guarantee fees September 2007 Treaty shopping - the next chapter July 2007 A new Canada-US tax convention June 2007 Budget proposals on interest deductibility for financing foreign affiliates delayed and deferred May 2007 The 2007 Federal Budget April 2007 Eligible Dividends - An Ongoing Issue March 2007 New regime for listed Canadian trusts and partnerships June 2006 Key issues in the federal Budget April 2006 How to defer tax on foreign spin-offs March 2006 Dividend tax rate cut to offset treatment of income trusts November 2005 Supreme Court renders judgments in GAAR appeals April 2005 Tax rates fall in federal Budget February 2005 Further relief for public company spin-offs December 2004 Good news for back-to-back cross-border loans November 2004 Budget legislation tightens certain income fund proposals September 2004 Supreme Court rules that interest expense is generally on account of capital July 2004 GAAR in Supreme Court and legislative spotlight June 2004 Legislation proposes extending limitation periods for federal tax debt collection May 2004 Non-resident investors targeted in income fund reform April 2004 What the new foreign affiliate changes will offer February 2004 New reasonable-expectation-of-profit rule December 2003 New foreign investment entity rules November 2003 Competent authority assistance under income tax treaties July 2003 CCRA rules favourably on non-resident-owned investment structures May 2003 Dissent rights in M&A and reorganization transactions April 2003 Federal Budget highlights March 2003 Income funds: tax-efficient investing February 2003 Auditor General targets international transactions December 2002 Harsh new rules for non-resident trusts and foreign investment entities November 2002 Interest deductibility relaxed October 2002 Supreme Court refuses to hear GAAR appeal September 2002 Resolving transfer pricing disputes July 2000 Changes to thin cap rules revisited June 2000 Non-residents with Canadian activities or dispositions must file Canadian tax return May 2000 The Queen v Dudney April 2000 Federal budget 2000 March 2000 Treaty-based information returns February 2000 CCRA issues final guidelines for regulation 105 waivers November 1999 Transfer pricing guidelines released June 1999 Recent court decision sows confusion May 1999 1999 Federal Budget December 1998 Draft international tax legislation October 1998 NON-RESIDENT WITHHOLDING September 1998 KIWI LOANS – AGAIN July 1998 FOREIGN ASSET REPORTING April 1998 BUDGET MODIFIED INTERNATIONAL TAX RULES March 1998 CANADA CROSSES THE BORDER

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