Course Synopsis


08:00-08:30 Continental Breakfast
08:30-12:30 Lectureship

Canada’s Income Tax Treaties

The subject of the 2008 IFA Canada Travelling Lectureship will be Canada’s income tax treaties. In particular, the focus will be on the application of tax treaties in and by Canada. The outline distributed to participants will consider a very broad range of issues arising under most articles of the typical Canadian tax convention. These include:

• The nature of tax treaties and their place within the Canadian legal system
• Scope and application of tax treaties
• Carrying on business in Canada
• Income from capital
• Canadian source remuneration
• Other income
• Tax on capital
• Relief from double taxation
• Non-discrimination
• Miscellaneous rules
• Administrative matters
• Competent authority procedure

The lecture itself will address a selection of these topics. The ambitious goal is to provide both a general overview of tax treaties and an examination of certain issues they raise.