The fourth edition of this highly successful book explores the "inbound" international tax issues of non-residents of 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 to properly advise their clients.

Other significant updates include:

• 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
• Expanded discussion on the changes that resulted from the Fifth Protocol to Canada-U.S. Treaty and CRA interpretations and statements since the last edition, including, particularly, expanded discussion of implications for hybrid entities such as LLCs and ULCs

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 find the content useful.

About the Author

Michael I. Atlas, C.A., C.P.A., T.E.P. is an accomplished author and long standing contributor to CCH. He is a Chartered Accountant who practices in Toronto as an independent tax consultant, in connection with a wide-range of domestic and international tax issues. 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 also 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. Most recently, Michael has made a presentation entitled "Tax Issues for Non-Resident Investors in Canadian Real Estate" as part of "Creative Tax Planning For Real Estat

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This webcast was recoreded on March 26, 2008

Cross-Border Tax Update will discuss a number of changes affecting Canadian tax laws that have recently been enacted or that are expected to come into force in 2008 and will have a significant impact on cross-border taxation.

This webinar is intended to provide valuable updates to those with at least an intermediate understanding of cross-border tax issues including those working in private practice and those working in-house.

Agenda

• Updates regarding the protocol to the Canada-U.S. Income Tax Convention
• The elimination of withholding tax on interest paid to non-residents
• Changes to the Canada Revenue Agency policy regarding amalgamations and non-residents
• The status of the foreign investment entity/non-resident trust rules
• Developments in the area of transfer pricing

The Speakers
Jules Lewy, LLB, is a Fraser Milner Casgrain LLP partner who focuses on all aspects of taxation, including corporate, international, and personal tax law, and frequently provides business and tax advice to owner-managed businesses, including advice on corporate reorganizations, acquisitions and divestitures.

Duane Milot, LLB, is a Fraser Milner Casgrain LLP lawyer whose practice focuses on general corporate income tax law for both domestic and international tax issues, and represents taxpayers in disputes with the Canada Revenue Agency and provincial tax authorities.

Christopher Steeves, LLB, is a Fraser Milner Casgrain LLP partner who practices tax law with particular expertise in the area of corporate restructurings and acquisitions involving Canadian businesses.

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• Changes to the “tie-breaker” rule for determining the residence of a corporation that qualifies as a resident of both Contracting States
• Entitlement to Treaty benefits for “fiscally transparent entities”
• New permanent establishment rules
• Elimination of withholding tax on certain interest payments
• Taxation of a non-resident’s emigrant gains
• Taxation of “income from employment” earned by non-residents
• Taxation of stock options received by individuals employed in both Canada and the United States
• Introduction of a reciprocal limitation of benefits provision

• Annotations of related Dominion Tax Cases
• Memorandum of Understanding between the Competent Authorities of Canada and the United States Regarding the Mutual Agreement Procedure
• Agreement between the Government of Canada and the Government of the United States of America with Respect to Social Security
• Income Tax Conventions Interpretation Act
• Rates of Withholding Tax under Income Tax Agreements Signed by Canada

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Available: November 2010

This book reflects all pertinent federal taxation changes that affect 2010 returns and provides fast and reliable answers to tax questions affecting individuals and business income tax.

The 2011 MTG contains timely and precise explanation of federal income taxes for individuals, partnerships, corporations, estates and trusts, as well as new rules established by key court decisions and the IRS.  Significant new tax developments are conveniently highlighted and concisely explained for quick reference and understanding.  The handbook's explanations are meticulously researched and footnoted to provide tax practitioners with the most accurate and legally sound guidance to help them understand, apply and comply with today's complex federal tax laws.

This handbook is built for speed with numerous time-saving features, including a tax calendar, taxpayer-specific return flowcharts, lists of average itemized deductions, selected depreciation tables, rate tables, checklists of income, deduction and medical expense items, and more.  These features help users quickly and easily determine how particular tax items and situations should be treated and answer client questions.

It comes complete with the popular Quick Tax Facts card that can be detached for at-a-glance reference to key tax figures and other often referenced amounts used in preparing 2010 income tax returns, and a special bonus CPE course supplement entitled "Top Federal Tax Issues for 2011," which focuses in on the most significant and thorniest new tax developments affecting practitioners for the year.  The Top Federal Tax Issues Course allows professionals to earn CPE credit while keeping up-to-date on the most important tax issues (grading fee additional).

The 2011 U.S. Master Tax Guide's updated explanations cover:

• Highlights of New Tax Developments
• Tax Rates and Tax Tables
• Individuals
• Corporations
• S Corporations
• Partnerships
• Trusts and Estates
• Exempt Organizations
• Income
• Exclusions from Income
• Business Expenses
• Non-Business Expenses
• Losses and Bad Debt
• Depreciation, Amortization and Depletion
• Tax Credits
• Minimum Tax
• Tax Accounting
• Basis for Gain or Loss
• Sales, Exchanges and Capital Gains
• Installment Sales/Deferred Payment Sales
• Securities Transactions
• Tax Shelters/At-Risk Rules/Passive Losses
• Retirement Plans
• Corporate Acquisitions/Reorganizations
• Taxation of Foreign Activities/Taxpayers
• Returns and Payment of Tax
• Withholding and Estimated Taxes
• Examination of Return

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Available: April 2012

Comprehensively analyzes all the tax laws applicable to individual retirement accounts. The first part of the book discusses the 15 different types of IRAs, including the four most recent types authorized by the tax laws: the Roth IRA, the education IRA, the SIMPLE IRA, and the deemed IRA. The second part discusses the various areas of tax law relating to the operation and administration of an IRA. There is a separate chapter on each area of the tax law. The third part of the book deals with taxation of distributions from an IRA, including premature distributions, minimum distributions during lifetime and after death, withholding taxes, and estate taxes. It also deals with the tax rules applicable to the different types of the beneficiaries receiving distributions from an IRA, including foreign beneficiaries, charitable beneficiaries, trust beneficiaries, estate beneficiaries, spouse and nonspouse beneficiaries, and individual and non-individual beneficiaries.

Related books:

• Federal Estate & Gift Taxes: Code & Regulations (Including Related Income Tax Provisions), As of 03/2012
• Estate Planning (2013 Edition) (U.S.) 
• U.S. Master Estate and Gift Tax Guide (2013) 
• Estate and Retirement Planning Answer Book, 2012 Ed. U.S.

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Available: August 2011

Professors Richard C. Pugh, Charles H. Gustafson, and Robert J. Peroni

Compiled by a team of distinguished law professors, the 2011-2012 edition of INTERNATIONAL INCOME TAXATION: Code and Regulations-Selected Sections serves both students and practitioners in accessing the laws and regulations for U.S. international tax. For students, the INTERNATIONAL INCOME TAXATION: Code and Regulations-Selected Sections is a popular companion to an international tax course book for use in undergraduate or graduate courses in law and business schools. For practitioners, the book is an exclusive convenient desk reference. Unlike the full multi-volume Internal Revenue Code and Income Tax Regulations, this single-volume reference travels well between home and office.

Includes CD of entire contents of book.

In this comprehensive and easy-to-use volume, the authors have selected provisions of the Internal Revenue Code and Income Tax Regulations directly related to the U.S. taxation of foreign entities and the U.S. taxation of domestic entities that have income from sources outside the country.

The 2011-2012 edition of INTERNATIONAL INCOME TAXATION: Code and Regulations-Selected Sections reflects all legislation and regulations enacted or adopted on or before June 1, 2011.

• 1040 Express Answers (2012)
• 1041 Express Answers (2012)
• 1065 Express Answers (2012)
• U.S. Master Tax Guide®,2012
• ProSystem fx Tax: for U.S. Tax Returns
• INTERNAL REVENUE CODE: Income, Estate, Gift, Employment and Excise Taxes, Winter 2012 Edition
• U.S. INCOME TAX REGULATIONS, Winter 2012 Edition

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Available June 2012

Part of the new CCH Beacon Series, Taxation of the Entertainment Industry 2012 is an insightful treatise that helps practitioners in entertainment tax planning:
• spot unique issues before they become problems,
• interpret rules and regulations correctly,
• make business decisions that lower taxes,
• and ensure compliance with the law.

This valuable reference by expert practitioner and author, Schuyler Moore, provides in-depth treatment of the taxation of film and television industries, including music and sports. It provides insights on proven strategies and techniques for achieving solid bottom-line results for those practitioners with clients within the entertainment industry.

Taxation of the Entertainment Industry sets forth details of an eight-point master plan for managing entertainment tax issues:
• Know how the law characterizes ownership rights and interests
• Choose a business form that provides maximum tax advantage
• Determine the best time to report and recognize income
• Reduce the tax burden through deductions, depreciation, and the investment tax credit
• Avoid liability for failure to withhold wages
• Realize tax deferral and tax savings through foreign production or distribution
• Discover innovative and creative strategies for financing film production and distribution, and 
• Pay close attention to the special tax considerations that apply to talent.

Moore thoroughly explains all of these issues, opportunities and challenges with clarity in this sure and steady guide through the ins and outs of entertainment tax law.

CONTENTS:
• Overview
• Fundamental Characterization Issues
• Choice of Entity
• Income Recognition, Timing and Characterization
• Deductions and Depreciation
• Wage Withholding
• Foreign Production and Distribution
• U.S. Tax Withholding on Foreign Persons
• Financing Using Domestic Tax Shelters
• Other Financing Methods
• Tax Planning for Talent
• California Taxation
• The Sports Industry
• The Music Industry
• Film Financing
• Forms

ABOUT THE AUTHOR:
Schuyler M. Moore is a partner in the Corporate Entertainment Department at the Los Angeles office of the national law firm of Stroock & Stroock & Lavan LLP.  He was the founding Chairman of the Entertainment Tax Subsection of the Los Angeles County Bar Association Taxation Section.  Mr. Moore holds undergraduate and law degrees from the University of California at Los Angeles, where he was first in his law class.  He has published numerous articles dealing with a wide variety of tax subjects and is the author of The Biz: The Basic Business, Legal and Financial Aspects of the Film Industry.  Mr. Moore is an adjunct professor for the UC

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CCH's Highlights of the American Recovery and Reinvestment Act of 2009 is a convenient vehicle for alerting clients to the new tax provisions provided under this economic stimulus bill. For individuals, this legislation includes a Making Work Pay Credit based on earned income, with a $250 economic stimulus payment to Social Security recipients and disabled veterans; an AMT patch for 2009; extension of the first-time homebuyer credit to September 1, 2009, with the repayment obligation eliminated for 2009 purchases; a $3,000 floor on the refundable Child Tax Credit; a $2,500 American Opportunity Tax Credit that is 40 percent refundable; suspension of income tax on up to $2,400 of unemployment benefits for 2009; expansion of eligible expenses for 529 plans to include computers and related technology; an above-the-line deduction for taxes related to the purchase of a new automobile; an increase in the credit for nonbusiness energy property from $500 to $1,500 and a modification of standards;  removal of the dollar limits on the credit for residential energy efficient property for fuel cell property; an increase in the credit for alternative fuel vehicle refueling property; and a general re-write of the plug-in electric drive motor vehicle credit, including elimination of dollar caps, a new credit for two or three wheel and low-speed plug-in vehicles, and allowing a credit for conversion kits.

On the business side, provisions include extending bonus depreciation and increased 179 expensing through 2009; up to five-year carryback of net operating losses; expansion of the Work Opportunity Tax Credit to cover unemployed veterans and disconnected youth; deferral of cancellation of indebtedness income; an increased exclusion amount for commuter transit benefits and transit passes; an increase in the capital gain exclusion percentage for qualified small business stock; and reduction to seven years for the S Corporation built-in gain holding period. The legislation also includes a number of new or enhanced bond provisions aimed at economic recovery and alternative energy.

CCH's Highlights booklet is ideal for informing clients, prospects and staff about the key new tax changes and prompting them to turn to their tax and financial advisers for help.  It's authoritative, yet practical and easy-to-understand.  Affordable quantity discounts and the option of printing firm name and logo on the cover make the CCH Highlights booklet a great tool for firms to grow their businesses.

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CCH's American Recovery and Reinvestment Act of 2009 -- Law, Explanation and Analysis provides thorough and complete text of added, amended, or repealed Code sections with controlling committee reports and CCH's explanation and analysis of tax provisions contained in the legislation. CCH editorial staff, along with leading practitioners, provide clear and practical guidance of the impact of the law's changes, including how various taxpayer groups and situations are affected.

The law is arranged in Code section sequence with italicized type used for all new language that amends previous Code sections. CCH also provides several special tables and lists to facilitate quick and thorough understanding of the new law and how it affects taxpayers. Features include an effective dates table organized by Code section, a listing by Code section of the Act sections affecting it, and a listing by Act section of the Code sections affected.

CCH's American Recovery and Reinvestment Act of 2009 -- Law, Explanation and Analysis is THE resource that tax professionals, businesses, government staff and students alike need to get all the details of and help on new tax legislation changes. CCH provides the critical, late-breaking explanation and analysis to help readers make sense of complex legislative change so they can plan, respond and advise with confidence.

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State Tax Guidebook Library Plan provides you with all 20 industry-leading State Tax Guidebooks, shipped immediately upon publication, all for one attractive annual subscription price nearly 50% off the regular list price. You'll receive all State Tax Guidebooks currently available and all new editions published within your subscription period and any new editions developed and published throughout the year during your subscription period.

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The taxation of natural resources is one of the more complicated areas of the U.S. federal income tax system. From the acquisition of the mineral rights, to the exploration and development of the property, to the ultimate production of the mineral, there are unusual and challenging tax aspects along every step of the way.

Oil and Gas: Federal Income Taxation (2011) is an invaluable single-source handbook for accounting, tax and legal practitioners concerned with financial issues related to oil and gas industry tax law.  

Updated and revised by noted oil and gas taxation authority and educator, Patrick A. Hennessee, Ph.D., CPA , this detailed reference is divided into six main sections:

• Introduction to Oil and Gas Taxation
• Acquisition of Interests
• The Exploration Period
• The Production Period
• Dispositions
• Other Areas

The text begins with a discussion of the nature of oil and gas reserves in order to gain a better understanding of the industry. The material following is organized in a logical sequence of events which traces the normal industry pattern for developing oil and gas reserves.

Special features include:

• A special ''Highlights of New Developments'' section provides a convenient, at-a-glance summary of recent tax legislation, case law, rulings, position papers, etc., as they relate to the oil and gas industry, and it tells readers where in the volume they can find additional information on the specific topics.
• Reflects all the recent developments in place, including new legislation, regulations and case law changes impacting this area since the previous edition published, allowing tax and legal professionals to stay current on this highly specialized area of tax law.  
• Enables understanding of the myriad technical aspects of oil and gas taxation by thoroughly discussing the critical issues of:
  • economic interests
  • lease and purchase arrangements
  • royalties
  • working or operating mineral interest
  • production payments
  • net profits arrangements
  • geological and geophysical expenses
  • intangible drilling and development costs
  • sharing arrangements and carried interests
  • depletion
  • gross income from property
  • taxable income from property
  • unitizations
  • disposition of interests
  • nontaxable exchanges
  • losses and abandonments
  • types of ownership
  • alternative minimum tax
  • nonconventional fuel credit
  • depreciation
  • a

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• Oil and Gas Tax Reporter Tax Trends Newsletter (monthly) - tracks federal energy legislation, IRS rulings, federal cases, state tax, and other developments.
• Multistate Oil and Gas Severance Tax Interactive Chart – allows you to quickly find the applicable oil or gas severance tax rates for any state jurisdiction, with citations to the state laws.
• Oil and Gas Tax Reporter – edited by industry experts, providing many illustrative examples and tax planning considerations for oil and gas ventures, citations to controlling authorities, and updated quarterly to reflect the latest developments. Covers the tax provisions unique to the oil and gas industry, from exploration, through development, the production phase, and sales and other dispositions of the properties. Includes coverage of issues unique to oil and gas companies in various areas, including tax credits, depreciation, and accounting methods.
• Internal Revenue Manual - Oil and Gas Handbook – IRS internal guidelines for the examination of income tax returns of taxpayers involved in the oil and gas industry.
• ISPs/MSSPs – IRS papers establishing examination uniformity within industry categories; the publication includes the IRS Audit Technique Guide for the Oil & Gas Industry.

Contact your CCH account manager today or contact Benoit Filion.

Content is divided into six main sections, organized to trace the industry pattern for developing oil and gas reserves – updated at least quarterly (more often as needed)

The content is easy to follow for practitioners familiar with the industry, as the presentation of the material mirrors the professional’s normal course or workflow, with an overview for each topic.

1.    Introduction to Oil and Gas Taxation             Chapter 1
2.    Acquisition of Interests                                    Chapters 2 -- 8
3.    The Exploration Period                                    Chapters 9 -- 10
4.    The Production Period                                     Chapters 11 -- 18
5.    Dispositions                                                      Chapters 19 -- 21
6.    Other Areas (losses and aba

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In Kess on Tax Legislation 2009: American Recovery and Reinvestment Act of 2009 CPE Course, noted tax experts Sidney Kess, J.D., CPA, and Barbara Weltman, J.D., take a straightforward and practical look at 2009 tax legislation and related developments. This text-based Course offers tax professionals helpful guidance on the new law, including planning opportunities, pitfalls to beware of, and ways practitioners can capitalize on the law with their clients. Helpful Practice Development Tips, Planning Pointers and Observations designed to assist users in understanding and applying the new law are peppered throughout. The Course comes complete with learning objectives, study problems and a final exam for use in earning valuable continuing education credits. The course will be divided into six chapters:

1. Changes for Individuals
2. Housing
3. Education and Health
4. Retirement Savings
5. Changes for Business
6. Miscellaneous
7. Changes

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In Kess on Tax Legislation 2009: American Recovery and Reinvestment Act of 2009 CPE Course, noted tax experts Sidney Kess, J.D., CPA, and Barbara Weltman, J.D., take a straightforward and practical look at 2009 tax legislation. This text-based Course offers tax professionals helpful guidance on the new law, including planning opportunities, pitfalls to beware of, and ways practitioners can capitalize on the law with their clients. Helpful Practice Development Tips, Planning Pointers and Observations designed to assist users in understanding and applying the new law are peppered throughout. The Course comes complete with learning objectives, study problems and a final exam for use in earning valuable continuing education credits. The course will be divided into six chapters:

1. Changes for Individuals
2. Housing
3. Education and Health
4. Retirement Savings
5. Changes for Business
6. Miscellaneous Changes

If you would like more details about this product, or would like to order a copy online, please click here.

How Canadian practitioners stay in the know about international tax issues

As the Canadian economy becomes increasingly global, international tax issues are affecting Canadians as never before. Practitioners ranging from the accounting professional to the international tax specialist count on International Tax to stay current and accurately informed.

This bi-monthly newsletter is packed with insights from international tax experts on all types of international tax issues – all from a Canadian perspective. It includes tax changes and new issues in areas such as:

• Determination of residency status
• Outbound/inbound investments
• Immigration/emigration for individuals
• Corporate immigration/emigration
• Impact of tax rules
• Foreign tax rules
• FIF rules
• NRT rules
• CRA Interpretation Bulletins

Editor-in-chief Sam J. Tyler, of KPMG Law LLP, leads an editorial team of Canadian international tax experts from both professional and academic fields.

• Free training and technical support

Wolters Kluwer CCH research subscriptions deliver the most timely, relevant and reliable tax information and commentary to Canada's tax professionals, significantly reducing research time.

Professionals who subscribe to International Tax newsletter also find these publications instrumental to their practice:

• Canadian Tax Reporter

Related Products

Schwarz on Tax Treaties, 3rd Edition
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INTERNATIONAL INCOME TAXATION: Code and Regulations - Selected Sections (2014-2015 Edition) (U.S.)
International Taxation: U.S. Taxation of Foreign Persons and Foreign Income (2014 Supplement)
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