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.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
The boutique Australian firm’s TP award recognition proves that world-class advisory services aren’t limited to the ‘big four’, the firm’s founder tells ITR
Canadian and Indian dual VAT models have been a source of inspiration for the Brazilian model, but the latter has unique and innovative features, the OECD paper claimed
More sophisticated use of technology, heightened TP scrutiny and stricter filing requirements are making South African Revenue Service audits a formidable challenge
One year after Nuwaru joined the WTS network, leaders James Jobson and Matthew Missaghi reflect on the firm’s mission to offer mid-tier pricing but deliver top-tier results
The US itself was the biggest loser of tax revenue to American multinationals’ profit shifting, the Tax Justice Network reported; in other news, firms made key tax hires
As multinationals embed tax technology into their TP functions, a new breed of systems – built on multi-model databases – is quietly transforming intercompany pricing logic