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International Tax Conventions

International Tax Conventions - Assessing and collecting...

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International Tax Conventions * Canadian taxpayers often invest, carry on business, or are employed in foreign jurisdictions that also impose income tax and foreign entities engage in similar activities in Canada * As a result, Canada has entered into reciprocal tax treaties with many foreign countries in order to o rationalize and deFne the jurisdictional authority on transactions of an international nature; and, o avoid the incidence of double taxation resulting from applicable provisions of tax legislation in two or more jurisdictions * When provisions of international treaties are in con±ict with the Income Tax Act, the international treaty takes precedence * ²ederal tax law is the responsibility of the Department of ²inance
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Unformatted text preview: * Assessing and collecting tax is the job of the CRA * In order to asses tax, the CRA must interpret the law, and its interpretations may sometimes con±ict with the intentions of the Income Tax Act * The CRA's interpretations of complex/controversial sections are made public though two primary publications - Interpretation Bulletins and Information Circulars * The interpretations published by the CRA are not law and can be disputed through the court system; however, they do re±ect current assessment policy and should always be an important factor when tax planning activities are being considered...
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