In Olympia Trust Company, 2014 TCC 372, the Tax Court of Canada held that the trustee (Olympia) of a self-directed registered retirement savings plan (RRSP), was liable under section 116 of the Income Tax Act (Canada) for withholding tax that was not remitted by or on behalf of non-resident vendors in the context of the sale of shares that were taxable Canadian property (TCP) where such shares were to be held as property of the RRSP.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap