9.3.2 [a] Arm’s Length StandardArticle 9 incorporates into the Treaty the arm’s length principles reflected and noted above in U.S. domestic law. In its most basic dimensions,...
Posted by The Accounting and Tax on 12/05/2017
At present we are in the midst of uncertain financial times. Owing to the uncertainties it was seen that the average Canadian debt balances rose by 2.3% in the 2016 3rd quarter, which...
Posted by The Accounting and Tax on 12/01/2017
Whether it be Replacement of your vehicle with a used car or buying a new car, it is always a big decision. It might be the second biggest one, following the decision to buy a house....
Posted by The Accounting and Tax on 12/01/2017
You might have thought to have a well-settled life financially. However, these would not happen automatically and you must realize that you need to act to make the same happen. We...
Posted by The Accounting and Tax on 10/23/2017
7.3.2 [a] Taxation of the Business Profits of a Canadian ResidentParagraph 1 of the Article VII of the Treaty provides that the business profits of a Canadian resident will only be...
Posted by The Accounting and Tax on 09/09/2017
7.3.1 [a] U.S. Taxation of Income of Foreign PersonsForeign persons generating income from U.S. sources are potentially subject to one, or both, of two U.S. federal taxation regimes....
Posted by The Accounting and Tax on 09/09/2017
Spending money can be fun. But you also need to realize that your spending habits are very important and in some ways determine your financial success. It is just as important as saving...
Posted by The Accounting and Tax on 09/07/2017
7.2.2 [a] Article Vii[1]Business Profits – Taxation of Profits Attributable to a permanent EstablishmentBusiness profits of a U.S. resident carrying on a business in Canada are...
Posted by The Accounting and Tax on 08/31/2017
7 . 2 . 1 (a)In general, the net business profits of a non-resident carrying on business or any other income generating activities in Canada are subject to the income tax imposed under...
Posted by The Accounting and Tax on 08/31/2017