Available: August 2011

Authors: Michael S. Schadewald, Ph.D., CPA and Robert J.Misey, Jr., J.D., MBA and LL.M.

Provides readers with a practical command of the tax issues raised by international transactions and how those issues are resolved by U.S. tax laws. The book emphasizes those areas generally accepted to be essential to tax practice.

The book is written primarily as a desk reference for tax practitioners and is organized into four parts.

Part I provides an overview of the U.S. system for taxing international transactions, and also discusses the U.S. jurisdictional rules and source-of-income rules.

Part II explains how the United States taxes the foreign activities of U.S. persons, and includes chapters on the foreign tax credit, deemed paid foreign tax credit, anti-deferral provisions, foreign currency translation and transactions, export tax benefits, planning for foreign operations, and state taxation of foreign operations.

Part III describes how the United States taxes the U.S. activities of foreign persons, including the taxation of U.S.-source investment-type income and U.S. trade or business activities, as well as planning for foreign-owned U.S. operations.

Finally, Part IV covers issues common to both outbound and inbound activities, including intercompany transfer pricing, tax treaties, cross-border mergers and acquisitions, and international tax practice and procedure.

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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: Michael S. Schadewald and Robert J. Misey, Jr.

Provides readers with a practical command of the tax issues raised by international transactions and how those issues are resolved by U.S. tax laws. The book emphasizes those areas generally accepted to be essentialto tax practice.

PART I: BASIC PRINCIPLES OF U.S. TAXATION OF INTERNATIONAL INCOME

• Overview of U.S. Taxation of International Transactions
• Tax Jurisdiction
• Source of Income Rules

PART II: TAXATION OF FOREIGN ACTIVITIES OF U.S. TAXPAYERS

• Foreign Tax Credit
• Deemed Paid Foreign Tax Credit
• Anti-Deferral Provisions
• Foreign Currency Translation and Transactions
• Export Benefits
• Planning for Foreign Operations
• State Taxation of Foreign Operations

PART III: TAXATION OF U.S. ACTIVITIES OF FOREIGN TAXPAYERS

• Foreign Persons Investing in the United States
• Foreign Persons Doing Business in the United States
• Planning for Foreign-Owned U.S. Operations

PART IV: TAXATION ISSUES IMPACTING BOTH U.S. AND FOREIGN TAXPAYERS

• Transfer Pricing
• Income Tax Treaties
• Cross-Border Transfers and Reorganizations
• International Tax Practice and Procedure

Appendices provide reproductions of applicable IRS forms and publications, as well as the latest U.S. Model Income Tax Treaty.

688 pages

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Transfer Pricing: Rules, Compliance and Controversy (4th Edition)
International Tax Newsletter

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Published: December 2011

Defending Class Actions in Canada, 3rd Edition is Canada’s top resource for enterprises exposed in any way to potential or actual class actions and for the lawyers who represent them.

Any company doing business in Canada will encounter growing enthusiasm for class actions among plaintiffs’ lawyers and the courts. This book outlines the procedural machinery of Canadian class actions and the law that governs them, provides strategic analysis on managing the risks they entail, and explains the most important recent developments and trends on a national and international scale.

The greatest strength of the book derives from its authorship by seasoned class action defence lawyers at McCarthy Tétrault, who practise as members of a national class actions defence practice group, often engaged together and with counsel in the United States and abroad in the defence of parallel actions involving similar allegations brought against the same entity in multiple separate jurisdictions.

Topics covered:

• Increased Accessibility of Class Proceedings
• Current Trends in Certification Standards
• The Evolution of Pre-Certification Defence Strategies
• State of Play for Multi-Jurisdictional Cases and the National Class
• What's New in Securities, Competition, and Product Liability Class Actions

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By popular demand, we are now offering an archived version of the webinar GST/HST & Real Property Transactions that took place on November 20, 2014.
 
Although many GST and HST concepts are well understood by taxpayers, many of the real property rules are less well known. The rules associated with real property are complicated, having led even tax practitioners astray, and the dollar values of these transactions are usually high. Accordingly, audit activity in the sector is also high and GST/HST errors have led to costly CRA reassessments.

Although many GST and HST concepts are well understood by taxpayers, many of the real property rules are less well known. The rules associated with real property are complicated, having led even tax practitioners astray, and the dollar values of these transactions are usually high. Accordingly, audit activity in the sector is also high and GST/HST errors have led to costly CRA reassessments.

This archived webinar will provide a practical understanding of the complex rules for real property transactions and the current issues faced by the industry in applying the GST/HST in the development, construction and sale of real property.

Topics specifically covered include:

• Current state of affairs
• Bare trustees
• Joint ventures
• Partnerships
• Sales of vacant land
• Self-assessments
• New housing rebates
• Rental property rebates
• Documentary requirements for input tax credits

By purchasing this archive webinar, you will receive:

• 30 days to review the webinar recording 

• PDF version of the presentation slides

Our Speaker: 

Wayne Mandel, PwC LLP

Wayne Mandel is an Indirect Tax Manager with PricewaterhouseCoopers LLP. He specializes in the Goods and Services Tax and the Harmonized Sales Tax and has concentrated his area of practice primarily in the real estate sector. Wayne has provided advice and interpretation on a wide range of issues and has also provided assistance to clients in preparing for government audits, support during the audit process and resolving assessment issues. Wayne has experience in the appeals process and making submissions under the government's taxpayer relief provisions. He has delivered numerous presentations to clients on changes and new developments in these taxes.

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Online Resource

Rotch Library - NA2542.4.L42 2020

"Good discussion of issues and examples of how to handle challenging situations."

"Very informative with practical applications."

- Maja Winter, Webinar Participant

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Webinar information current as of June 17, 2008  

This archived webinar is designed to help you learn techniques and strategies not only for diffusing others but for managing your own emotions at these challenging moments. With these skills, you’ll be able to tackle everything from figuring out your own triggers and what your body language conveys, to boundary setting during a challenging conversation, to finding the right time and place to initiate a difficult interaction. Our goal is to help you keep your cool and approach those difficult situations with more confidence, so you resolve them more effectively and show your employees that you’re proactive in creating a tension-free workplace.

Learn how to:

• Manage yourself during difficult interactions
• Be proactive vs. reactive
• Understand your triggers and sync your body language to your message
• Plan the right time and place for a challenging conversation
• Master the art of constructive feedback
• Know when to use empathy, sympathy and apology

Speaker

Bina Feldman is a corporate training consultant and coach specializing in Personal & Professional Development. She holds a Bachelor of Arts and Master’s Degree in Communication Disorders. She is a member of the Canadian Society of Training & Development (CSTD) In the field of Training and Development since 1984, Bina has grown her business to deliver training across many industries and in the public sector. As a performance coach, she has helped business and professional people with communication and leadership skills.

Bina taught Presentation Skills and Public Speaking at the University of Toronto, School of Continuing Studies from 1981 – 1992 and has delivered Presentation Skills training nationally and internationally. Bina leads a training company and con

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