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• Changes to the “tie-breaker” rule for determining the residence of a corporation that qualifies as a resident of both Contracting States
• Entitlement to Treaty benefits for “fiscally transparent entities”
• New permanent establishment rules
• Elimination of withholding tax on certain interest payments
• Taxation of a non-resident’s emigrant gains
• Taxation of “income from employment” earned by non-residents
• Taxation of stock options received by individuals employed in both Canada and the United States
• Introduction of a reciprocal limitation of benefits provision

• Annotations of related Dominion Tax Cases
• Memorandum of Understanding between the Competent Authorities of Canada and the United States Regarding the Mutual Agreement Procedure
• Agreement between the Government of Canada and the Government of the United States of America with Respect to Social Security
• Income Tax Conventions Interpretation Act
• Rates of Withholding Tax under Income Tax Agreements Signed by Canada

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The spring 2010 edition of the Canadian Income Tax Act with Regulations, Annotated is filled with up-to-date content and legislative changes that make it indispensable for tax professionals. Featuring improved navigation, this new edition makes it even easier to find the answers you need to make smarter decisions, faster.

The 89th edition is updated and expanded to include significant developments since the last edition.

• The full text of the Income Tax Act and Regulations as amended to date of publication
• Pending amendments to the Income Tax Act
• Department of Finance comfort letters
• News releases 
• Editorial notes, as well as cross-references to other sources of information, including:
  
  • Related sections of the Act and Regulations
  • Bulletins, Circulars and Technical News Advance Rulings
  • CRA forms and guides
  • CCH newsletter articles
  • Canadian Tax Foundation articles
  • Canadian Petroleum Tax Journal articles
  • Key case annotations
  • Full text history notes
• Canada-U.S. and Canada-U.K. Tax Conventions as amended by Protocols
  • With full text history notes
  • including the technical explanations to  the Canada-U.S. Tax Convention and Protocols
• Interpretation Act 
• The Income Tax Conventions Interpretation Act
• Remission orders 
• Quick reference charts including rates, credits, limits and penalties

Other features in this edition making it easier and faster to use:

• Shading of:
  • proposed legislation,
  • comfort letters,
  • news releases, and
  • budget extracts
• Tax calendar
• Integration tables from PricewaterhouseCoopers LLP
• 2010 Tax Rates and Credit Tables from PricewaterhouseCoopers LLP

Editorial Board - As of November 2009

Joseph Frankovic LL.B., LL.M., Ph.D., CFA
Member of the Ontario Bar and the adjunct faculty of Osgoode Hall Law School

Larry Murray B. Comm. F.C.A.

Fraser Milner Casgrain LLP
       William I. Innes LL.B., LL.M
       Jules Lewy B.C.L., LL.B.
       Tony Schweitzer LL.B., LL.M.
       Christopher Steeves LL.B.

Minden Gross LLP
       David Louis B.Com., J.D., C.A. 
       Michael Goldberg B.Comm. Hons., LL.B. 
       Samantha Prasad B.A., LL.B. 
       
PricewaterhouseCoopers LLP
       Ruby Lim C.A.
       Sheyl Mapa C.A. <

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Your business is e-volving at a rapid pace and the tax implications are often overwhelming. It's complex, and you know you need to stay connected, but how? CCH is once again providing you with leading edge solutions and is proud to bring you the first authoritative reference book of it's kind: GST and E-Commerce: Planning and Risk Management. You'll find volumes of basic and detailed information in one convenient, targeted source. It will connect you with relevant, critical information about GST/HST in Canada. If you're doing business online, or advising someone who does, you need this book!

Target Audience

• Companies that sell or distribute products or services through the Internet
• Companies that purchase or consume products or services that are supplied through the Internet
• Companies that promote or advertise through the Internet
• Companies that do anything remotely by electronic means, including remote hosting, data backup, transmission, remote access to software or servers, remote security, and remote file sharing

Features include:

• Comprehensive discussion of the manner in which the GST applies to e-commerce activities of every nature
• Detailed review of CRA e-commerce rulings and formal administrative policies issued in the past five years
• Discussion of CRA policy imperatives and the manner in which these imperatives impact on the taxation of e-commerce
• Identification of e-commerce trends, limitations, anomalous results and outstanding issues to be resolved
• Focus on threshold and other contentious issues including jurisdictional issues
• Discussion of carrying on business and permanent establishment tests in the e-commerce environment
• Discussion of audit patterns and leading exposure issues
• Exploration of planning opportunities for resident and non-resident businesses

Each topic includes a review of the current legislation and Canada Revenue Agency rulings and other documents.

Table of Contents

• Chapter 1 – Overview of the Book and Evolution of E-Commerce GST Rules
• Chapter 2 – Overview of the GST
• Chapter 3 – Characterization of Supply
• Chapter 4 – Single Versus Multiple Supplies
• Chapter 5 – Place of Supply
• Chapter 6 – Zero-Rating
• Chapter 7 – GST Registration and the Non-Resident Override
• Chapter 8 – Permanent Establishment Issues
• Chapter 9 – Carrying on Business in Canada
• Chapter 10 – Agency
• Chapter 11 – Introduction to the Rulings Chapters
• Chapter 12 – Advertising Services
• Chapter 13 – Third Party Sales of Goods
• Chapter 14 – Software and Software Related Offerings
• Chapter 15 – Telecommunication Services

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Written by one of Canada's most respected practitioners in the area of commodity taxation, this new edition has been highly anticipated. First published in 2001, then in 2004, and most recently in 2008, this edition has been extensively revised and updated.

GST/HST and Real Property in Canada is an excellent quick reference book that outlines how the rules of GST/HST treat real property transactions in Canada. This book is an essential resource for practitioners involved in real estate transactions or commodity taxation.

Topics covered:

• Taxable supplies of real property
• Exempt supplies of real property
• GST/HST rules depending on how the ownership of property is held
• Special Situations such as repossessions and seizures, elections
• GST/HST rate changes

Table of Contents (subject to change)
Chapter 1: Definitions

• 1.1 – Builder
• 1.2 – Business
• 1.3 – Capital Property
• 1.4 – Commercial Activity
• 1.5 – Fair Market Value
• 1.6 – Person
• 1.7 – Personal Property
• 1.8 – Property
• 1.9 – Real Property
• 1.10 – Recipient
• 1.11 – Residential Complex
• 1.12 – Residential Unit
• 1.13 – Sale
• 1.14 – Supply

Chapter 2: Taxable Supplies of Real Property

• 2.1 – General Principle
  2.1.1 – Timing of Payment of Tax
  2.1.2 – Collection and Remittance of Tax
  2.1.3 – Place of Supply
  2.1.4 – Service in Respect of Supplies of Real Property
  2.1.5 – Deposits
• 2.2 – Sales of New Residential Housing
  2.2.1 – Adjustments to Purchase on Closing
• 2.3 – New Housing Rebates
  2.3.1 – Rebate for New Housing
  2.3.2 – Rebate for Cooperative Housing
  2.3.3 – Rebate for Owner-Built Homes
  2.3.4 – Rebate to Owner or Lessee of Land Leased for Residential Purposes
• 2.4 – New Residential Rental Property Rebate
  2.4.1 – Rebate for New Residential Properties
  2.4.2 – Temporary Rentals before Sale
  2.4.3 – Land Leased for Residential Purpose
  2.4.4 – Administration of the Rebate
• 2.5 – PST Transitional New Housing Rebate
• 2.6 – Development of Residential Real Property
  2.6.1 – Renovations and Self-Supplies
  2.6.2 – Substantial Renovation
  2.6.3 – Non-Substantial Renovation
  2.6.4 – Planning Point
  2.6.5 – Substantial Completion
  2.6.6 – Self-Supply of Single Unit Residential Complex or Residential Condominium Unit
  2.6.7 – Self-Supply of Residential Condominium Unit
  2.6.8 – Self-Supply of Multiple Unit Residential Complex
  2.6.9 – Self-Supply of Addition to Multiple Unit Residential Building
  2.6.10 – Self-Supply Rules: Exception for Personal Use
  2.6.11 – Self-Supply Rules: Exception for Student Residence
  2.6.12 – Sel

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The Canada Revenue Agency (CRA) issues income tax interpretation bulletins (ITs) to provide technical interpretations and positions regarding certain provisions contained in income tax law. Due to their technical nature, ITs are used primarily by CRA staff and tax specialists. An interpretation or position contained in an IT generally applies as of the date on which it was published, unless otherwise specified.

If you seek to provide the optimal solution on income tax related matters, then you need these invaluable resources. Income Tax Bulletins, Circulars, and Technical News is the only comprehensive print reference book that consolidates the Canada Revenue Agency's interpretations of the Income Tax Act; CRA procedures, practices, and administration policies; and CRA's position on recent court decisions. It offers three separate indexes to assist you in searching for the information you need fast.

• The Topical Index references specific topics of interest.
• The Sectional Index allows you to search for a document applicable to a provision in the Income Tax Act
• The Numerical Finding Index references the exact page of the circular, bulletin, or technical news that you need

This reference book is produced annually. The 2009 edition is consolidated to May 29, 2009.

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Introduction to Federal Income Taxation in Canada, 30th Edition gives you a smart learning advantage – here’s how:

• Each chapter includes examples, problems, multiple choice questions, and exercises designed to reinforce the material and text comprehension – with solutions provided for the student
• Review questions throughout the textbook include discussion notes at the end of the book
• Assignment problems and advisory cases have solutions provided in the Instructor’s Solutions Manual
• Student DVD includes extra problems and solutions for self-study
• CCH research software and CANTAX software also included on DVD

Income Tax Act compliant

Students dedicated to taxation and students interested in developing a solid general understanding of federal tax law will benefit from this resource. The contents are arranged in a sequence that follows the organization of the Income Tax Act for easy cross-referencing.

Reality checked

We know accuracy is critical and we pride ourselves on providing the most accurate and current content.

• Updated annually to reflect Budget and other legislative changes to income tax provisions
• All assignment materials have been carefully prepared and tested

Robert E. Beam, F.C.A., is a Professor Emeritus in the School of Accounting and Finance, University of Waterloo. He was associated with Ernst & Young, Chartered Accountants, Toronto.

From 1972 to 1998, he was Coordinator of the Tax Section of the School of Accountancy, Institute of Chartered Accountants of Ontario. In September 2002, Mr. Beam became the first recipient of the Canadian Institute of Chartered Accountants Award for Excellence in Tax Practice and Education. His articles have appeared in the Canadian Tax Journal.

Stanley N. Laiken, Ph.D., is the Deloitte Professor in the School of Accounting and Finance, University of Waterloo. He has taught taxation to students in professional programs, both at the university and post-university levels, since 1972.

He is a recipient of the Distinguished Teacher Award at the University of Waterloo and the Canadian Academic Accounting Association’s L.S. Rosen Award in recognition of outstanding contributions to Canadian accounting education. His articles have appeared in the Canadian Tax Journal. He is also the Director of the Deloitte Centre for Tax Education and Research at the University of Waterloo.

James J. Barnett, F.C.A., is the Director of the School of Accounting and Finance, University of Waterloo. Before taking on this role, he was the founding Director of the Master of Taxation program. He has taught taxation at the University of Waterloo since 1990. Prior to teaching, he spe

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Now in its second edition!

Preparing Your Trust Tax Returns is updated annually and provides the most current, detailed information available. It contains the same features, content and editorial excellence you have come to expect from CCH Canadian’s professional tax preparation guide.

Features & Coverage:

• Context-sensitive links from Taxprep and CANTAX software to the commentary in the DVD and online formats
  • Saves you time by putting search at your finger tips
• More topics in detail than any other guides available
• Easy-to-understand format lets you find what you need

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Features include:

• Helpful, time-saving commentary on all major provincial taxes
• A free monthly newsletter to keep you up-to-date on the newest tax changes. It contains practical feature articles and columns written by prominent practitioners, including Brent Jay of PricewaterhouseCoopers LLP and the experts at Ryan (formerly Robert Brakel & Associates)
• Budget dispatches for every province and territory, an important service offered only by CCH
• Federal and provincial tax charts, tables of concordance (Ontario and Quebec only), and a number of helpful research and reference tools
• And since every province and territory is covered, you can have this "must-have" publication wherever you conduct business in Canada
• New case comments in the electronic Ontario Tax Reporter on key Ontario cases. Comments authored by Chia-yi and Mark Osbalderston

Loose leaf and DVD updated monthly. Internet updated continuously.

About the Authors
The CCH editorial staff include Krista Fox, LLB (Quebec Tax Reporter); Candra Anttila, LLB (Ontario Tax Reporter); Peter Tomlinson, LLB (British Columbia Tax Reporter and Alberta & Territories Tax Reporter); Ben Dory, LLB (Atlantic Tax Reporter); and Louise Edwards (Manitoba & Saskatchewan Tax Reporter), with external author Lori Adams, LLB.

With more than 30 years of experience in dealing with Canadian sales taxes, the firm of Ryan is widely recognized as the foremost authority on the subject. Their commentary on sales tax for Ontario and Quebec (added in 2004) and for British Columbia (added in 2005) provides current and comprehensive coverage, including interpretation of legistation and administrative practices.

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The Supreme Court of Canada has delivered judgments in two critical cases involving the General Anti-Avoidance Rule. These long-awaited decisions are the most important developments in tax law in the past decade. Are you on the right side of GAAR?

History
When GAAR was introduced in 1988, it gave Revenue Canada very broad powers to challenge perceived tax avoidance activity. And since its genesis, there have been many justifiable concerns regarding GAAR's impact on tax planning. The bottom line is that GAAR has the power to affect any transaction that has the purpose of eliminating or reducing tax. But there has been little in the way of practical guidance to make informed planning decisions – until now.

The Essential GAAR Manual: Policies, Principles and Procedures is written by Canada's most highly regarded team of experts on GAAR issues at Fraser Milner Casgrain LLP: William I. Innes, LLB, LLM; Patrick J. Boyle, LLB; and Joel Nitikman, LLB, LLM. It was designed with your tax planning practice in mind and includes useful and accessible reference tools that will arm you with the knowledge and insight to inform your clients properly. It answers questions that will affect your tax planning strategies, such as:

• What's the future of GAAR after Canada Trustco and Mathew?
• What's a "textual, contextual and purposive" analysis?
• What does the Supreme Court of Canada mean by requiring that tax measures be "predictable"?
• What is the future of corporate tax planning?
• What is the future of family and estate planning?
• How will commercial tax shelters fare under the "new" GAAR analysis?
• How does a practitioner cope with the post-Canada Trustco climate?
• How do you document a transaction that may be probed by GAAR?

The author team goes beyond a descriptive and substantive analysis and provides you with key insights into the practical application of GAAR considerations for your day-to-day practice. As the application evolves, the CRA is likely to invoke GAAR with more frequency.

Resources

• The Bottom Line Magazine: Canada's premier newspaper for accountants – The Essential GAAR Manual
• CCH Publishes First Comprehensive GAAR Manual (11/04/2006)

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An indispensable guide with substantial changes and important updates.

The Estate Planner's Handbook provides a concise yet comprehensive overview of many of the most important issues in the estate planning process. It will aid estate planners, lawyers, accountants and other professional advisors in identifying critical updates that they need to be aware of and will prove to be invaluable in developing creative estate planning solutions.

New and emerging issues in the Estate Planning field

The third edition of The Estate Planner's Handbook covers a wide range of topics, including a new chapter on estate planning for the disabled that addresses the use of planning vehicles provided by the Income Tax Act (such as Lifetime Benefit Trusts and Registered Disability Savings Plans) and Henson trusts designed to safeguard access to provincial income support programs. This highly anticipated edition contains substantial changes in the form of budgetary pronouncements, legislative changes, new case law and CRA administrative positions impacting estate planning. These changes include but are not restricted to issues such as:

• Changes to case law relating to jointly held property, life insurance and the attribution rules
• The introduction of Tax Free Savings Accounts, Registered Disability Savings Plans, Lifetime Benefit Trusts and pension income splitting
• Legislative changes impacting taxation of charitable donations, the age at which RRSPs must mature and the capital gains exemption
• Probate tax changes
• Pending amendments re: non-resident trusts

Essential topics in the estate planning process addressed in this edition include:

• Wills
• Multiple Wills
• Will Substitutes
• Continuing Powers of Attorney
• Health and Personal Care by Proxy
• Some Basic Trust Law Concepts & Principles
• Taxation of Basic Trusts Used in Estate Planning
• Certain Other Trusts Used in Estate Planning
• Charitable Donations
• Taxation at Death
• United States Estate & Gift Tax
• Probate
• Dependants' Relief
• Spousal Property Rights in Ontario

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Value-Added Taxation in Canada provides practitioners with a complete easy-reference guide to the application of the Goods and Services Tax, its harmonized counterpart applicable currently in Nova Scotia, New Brunswick and Newfoundland and Labrador, and the Quebec Sales Tax. Since the last edition published in 2003, significant changes have taken place in the areas of GST, HST and QST, including two GST and HST rate reductions and the recent announcement by Ontario and British Columbia of their intention to harmonize their provincial sales taxes with the federal GST.

This new edition includes comprehensive commentary prepared by Ryan, a recognized authority on Canadian sales taxes. The commentary reflects the changes since the last edition, including proposals contained in the various Federal Budgets and draft legislation issued to the date of publication.

The book addresses both practical and theoretical issues with an emphasis on practical applications for private and public sector taxpayers.

In order to help practitioners better understand the intricacies of the GST, HST and QST, the authors have taken an integrated approach; discussing the impact of the three taxes on each topical area.

Table of Contents (Condensed)

CHAPTER 1 – INTRODUCTION
CHAPTER 2 – REGISTRATION
CHAPTER 3 – SUPPLY
CHAPTER 4 – PLACE OF SUPPLY
CHAPTER 5 – VALUE OF CONSIDERATION
CHAPTER 6 – WHEN TAX IS PAYABLE
CHAPTER 7 – IMPORTS AND INTERPROVINCIAL TRANSFERS
CHAPTER 8 – EXEMPT SUPPLIES
CHAPTER 9 – ZERO-RATED SUPPLIES
CHAPTER 10 – INPUT TAX CREDITS AND INPUT TAX REFUNDS
CHAPTER 11 – REBATES
CHAPTER 12 – ORGANIZATIONAL CONSIDERATIONS
CHAPTER 13 – FINANCIAL INSTITUTIONS
CHAPTER 14 – INDUSTRY-SPECIFIC ISSUES
CHAPTER 15 – COLLECTION AND REMITTANCE OF TAX
CHAPTER 16 – ADMINISTRATION AND ENFORCEMENT

About the Author:

Ryan is the leading tax services firm in North America, with the largest transaction tax practice in the United States and Canada. Since 1974, the firm's Canadian practice, located in Mississauga, Ontario, has performed work for more than 5500 organizations on a variety of tax matters, both provincially and nationally. Headquartered in Dallas, Texas, the firm provides a comprehensive range of state, local, federal, and international tax advisory and consulting services on a multi- jurisdictional basis, including audit defense, tax recovery, credits and incentives, tax process improvement and automation, tax appeals, and strategic planning. With a multi-disciplinary team of more than 800 professionals and associates, Ryan serves many of the world's most prominent Fortu

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