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Kevin Shoom on BEPS
Miscellaneous correspondence
., R & D) in-house, then this nexus ratio would be equal to one. That ratio is then applied to the overall income from the IP asset, to determine the amount of income which is eligible to receive benefits under a preferential regime. ...
20 November 2017 CTF Annual Conference - Department of Finance on BEPS
Miscellaneous correspondence
In the first scenario of entry into force on December 1, 2018, there would then be an entry into effect in Canada, with respect to withholding taxes, on January 1, 2019 – which, of course, assumes that there is a match with another jurisdiction where the instrument is in force by then. ...
23 February 2016 Toronto Centre Tax Professionals - Approach to Large Business Audit Compliance - Update
Miscellaneous correspondence
The presenters were: Gord Parr, Director, Large Business Audit Division, International and Large Business Directorate, Compliance Programs Branch Andrew Kingissepp, Partner, Taxation, Osler, Hoskin & Harcourt LLP Certain questions that briefly introduced the topics (e.g. ...