Article 27

Cases

Hillis v. Canada (Attorney General), 2015 FC 1082

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Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Hansard, explanatory notes, etc. regard to object rather than political statements 49
Tax Topics - Treaties - Income Tax Conventions - Article 25 FATCA requirements were reciprocal and were primarily imposed on financial institutions 166
Tax Topics - Treaties - Income Tax Conventions - Article 26A Art. 26 of US Convention did not prohibit FATCA information exchanges 158

Pacific Network Services Ltd. v. MNR, 2002 DTC 7585 (FCTD)

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See Also

Derrin Brothers Properties Ltd & Ors, R (on the application of) v A Judge of the First Tier Tribunal (Tax Chamber) & Ors, [2016] BTC 10, [2016] EWCA Civ 15

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 231.2 - Subsection 231.2(3) third party notices to UK accounting firm and banks did not require them to be given explanation why information required 849

Administrative Policy

5 April 2015 CRA Press Release (respecting Panama Papers)

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22 March 2016 Internal T.I. 2016-0632941I7 - BEPS exchange of tax rulings

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88 C.R. - F.Q.16

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88 C.R. - F.Q.18

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Articles

Gouin-Toussaint, "Revenue Canada's International Tax Programs Directorate", Tax Profile, October 1992.

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