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Taxation of International Performing Artistes
The special tax rules for performing artistes lead to obstacles. This book considers the problems regarding, for example, the determination of taxable income and the non-deductibility of expenses and tax credits in the country of residence, and gives clear examples of excessive taxation.
The Canada Income Tax Act: Enforcement, Collection, Prosecution - 2021 Edition (slightly updated) ... I made my life on this "World" since first seeing Kim Scott Neufeld in 1987, as She taught me the ITA in Tax Won at Concordia U.. (Or, tried to. I wasn't the smartest cookie back then: still not, but when you only want to make Kim smile, make her happy, and win her heart and mind, like she did mine, you will write entire books for Her.) https://www.youtube.com/watch?v=IOrxEvSFyPs&list=RDIOrxEvSFyPs&start_radio=1 XO for Xmas 2025 Kim https://www.youtube.com/watch?v=6ATFJroe1OQ https://www.youtube.com/watch?v=vgC23R3g4tE&list=RDvgC23R3g4tE&start_radio=1 That's why I'll talk to Her and Her alone, before anyone: if I'm a key, then She's The Key to me. That's why it has to be You Kim: not a substitute - In Kim I Trust, 'the brainiac gal' who got me into the professional CALLING of tax imposition in 1987 - the legally compellable PAYMENT of part of the 'fruits of our labour' for the benefit of ALL of us, who led me, in love of Her, to write my primary books on tax case, state-of-the-Art for their era - that I never once advised on or made a dime from, though costing me hugely, as also labours of love, to then take on a puny portion of Montreal's 'dis-organized crime' as well as fulfilling my desire to pick-up the CFE (FINALLY, full circle, in love with Her, and our law - see the breadth of my work-product on Googlebooks). https://www.youtube.com/watch?v=GJJS5ser3k0&list=RDFL-SSdkbKm0&index=5 - same guy Kim, who staulked You and kept my eyes open for You, ALL OVER MONTREAL '87-93, and all the time after as well. Made it to 2025! All the Way, from 1987 Youngster! https://www.youtube.com/watch?v=v-JsqKlVVGk&list=RDv-JsqKlVVGk&start_radio=1
An updated, helpful lay-out of the 2021 provisions w/ case on Canadian Income tax collection. A simple case book on ITA tax collection. Anyone could do this: consume w/ passion the caselaw to examine how it applies w/ our Act to our evolving World. I DID, because it forms illustrative background of how our funding is realized. A great picture of a great Act. https://www.youtube.com/watch?v=NQYOJ9MWTbg A certain norm, standard, how could I treat you as only a Tax I teacher? https://www.youtube.com/watch?v=L_dVEtLPdDE As I built my career and old life on you, taking up all that I projected out you'd develop into, not having seen you since 1992. My old old life...Merry Chrtistmas Kim. In such a...
How Fixed Is a Permanent Establishment?
Permanent establishment is the key concept for allocating taxation rights in respect of business income, and the question ‘Is there a permanent establishment?’ is a tax treaty issue that advisers, government officials, and courts perennially confront. Based on a ‘fixed link to the ground’, the idea has become progressively more difficult to apply until, at this stage, re-evaluation has become a political necessity. If a permanent establishment may exist in the context of e-commerce, the concept of a geographical presence must be redefined. However, the question remains: Is e-commerce a sufficient reason for challenging the well-established permanent establishment nexus? Drawing on ca...
The Bar Register
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Canadian Tax Journal
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