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Canadian Taxation of
Non-Residents, 4th Edition |
The fourth edition of this highly
successful book explores the inbound international tax issues of non-residents
in 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.
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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 Estate Transactions" for
Federated Press on January 26, 2011.
He is also the author of many
articles that have appeared in CCH's Tax Topics. His most recent contribution
to CCH's Tax Topics was in issue 1986 on April 1, 2010, entitled “Federal
Budget Limits Scope of ‘Taxable Canadian Property’ and Creates
'FIRPTA Canadian Style’.” In addition, he was co-editor (together
with David Louis and Brian Nichols) of CCH's “Estate Planning in the
Twenty-First Century” series, which appeared bi-monthly in several of its
publications. Michael was also co-author of CCH’s “Canadian Taxation
of Real Estate (4th Ed.)” with Ian MacInnis.
Furthermore, he
presented a highly successful webinar for CCH on December 14, 2010 entitled
“Offshore Tax Planning: There’s Still a Lot Left.” Also, on
March 2, 2010, together with Robert Misey Jr., he presented an audio seminar
for CCH’s U.S. affiliate entitled “Canada–U.S. Cross-Border
Issues and Strategies.”
Michael is a graduate of the University of
Texas at Austin and a member of the Institute of Chartered Accountants of
Ontario. In addition, he is a U.S.-Certified Public Accountant (Illinois).
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| DESCRIPTION |
| Author |
Michael I. Atlas |
| Publisher |
CCH |
| Year of release |
2011 |
| Format |
Softcover |
| Pages |
400 pages |
| Catalogue No. |
B811 |
| Price |
110.00$ |
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| Available in French |
No |
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