The German giant may build a new Verbund site in Guangdong, China

Numerous basic inputs may be hit with a 10% import tax as trade war intensifies

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

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

Non-Residents, Cross-Border Transactions, and the GST is an invaluable resource for anyone involved with GST/HST issues concerning non-residents. This book provides practical guidance for non-residents of Canada that deal with Canadian customers or products, or carry on business in Canada, and need to know how the GST/HST applies to them. Non-Residents, Cross-Border Transactions, and the GST is a useful addition to the library of anyone who deals with non-residents including commodity tax practitioners, controllers, and business owners.

Key topics discussed in the book include:

• Drop-shipments
• Non-resident override rule
• Place of supply rules
• Cross-border transactions
• Imports and exports
• De facto importer rules
• Permanent establishments and carrying on business in Canada
• Recovery of tax by non-residents

The book contains clear explanations of fundamental topics, with numerous examples, especially on the application of the tricky drop-shipment rules. Also contains a detailed topical index.

Steven K. D'Arcy is a lawyer and a partner in Bennett Jones LLP, one of Canada's leading business law firms. His practice involves all areas of commodity tax with particular emphasis on the goods and services tax, Canadian customs laws, provincial retail sales tax, and anti-dumping duties.

In his GST practice, Steven advises on all facets of the GST legislation with emphasis on corporate transactions, particularly cross-border transactions. He has represented clients on numerous occasions with respect to GST assessments and proposed assessments. Steven served as counsel to the House of Commons Standing Committee on Finance with respect to its review of alternatives to the GST and has frequently provided advice to the Department of Finance with respect to proposed GST amendments.

Steven was recently recognized as a leading Canadian tax practitioner in indirect taxes in the International Tax Review's World Tax 2005. He is annually recognized in LEXPERT®/American Lawyer's Guide to the Leading 500 Lawyers in Canada, is also recognized in LEXPERT's Canadian Legal Directory as one of Canada's most frequently recommended commodity tax/customs practitioners, and is consistently recommended as an international trade regulation practitioner. Steven co-developed the Canadian Institute of Chartered Accountants annual "In-Residence GST Course", and currently teaches Part II of the course. He is an editor of the CCH GOODS AND SERVICES TAX REPORTER and the monthly GST Monitor.

He lives in Oakville, Ontario with his wife Susanna and their three children, Charlotte, Polly, and Duncan.

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Authors: Paul R. Comeau, Esq.,
                Mark S. Klein, Esq. and
                Timothy P. Noonan, Esq.

• An Overview of New York's Residency Rules
• An Overview of New York's Nonresident Income Allocation Rules
• Audit Issues: How to Handle (or Avoid) a NY Residency Audit
• Tax Penalties, Tax Crimes and Tax Enforcement: You May Owe More - A Lot More - Than Just Taxes
• New York's Withholding Guidelines
• A State-by-State Tax Guide for Former New Yorkers
• Appendix I Nonresident Audit Guidelines
• Appendix II Nonresident Allocation Guidelines
• Appendix III Criminal Prosecution of Tax Fraud Cases-Guidelines
• Appendix IV Withholding Tax Field Audit Guidelines

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