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Canadian Taxation of Non-Residents, 4th Edition

Canadian Taxation of Non-Residents, 4th Edition

Author: Michael I. Atlas
Publisher: CCH Canada
ISBN: 9781554963317
Published In: January 2011
Format: Paperback
Jurisdiction: Canada ? Disclaimer:
Countri(es) stated herein are used as reference only

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The fourth edition of this highly successful book explores the "inbound" international tax issues of non-residents of Canada who derive income from Canadian sources. Tax issues are analyzed in terms of the application of the relevant sections of the Income Tax Act and provincial statutes, the application of the Canada–U.S. Income Tax Convention, and the application of Canada's other tax treaties.

This edition has been updated with new case law and recent changes to legislation and CRA pronouncements for practitioners who deal with the subject matter and need to stay current on the issues to properly advise their clients.

Other significant updates include:

Changes to the definition of "taxable Canadian property" and the resulting implications for non-residents who invest in Canadian property or realize capital gains from Canadian sources
Expanded discussion on the changes that resulted from the Fifth Protocol to Canada-U.S. Treaty and CRA interpretations and statements since the last edition, including, particularly, expanded discussion of implications for hybrid entities such as LLCs and ULCs

Discussions and commentary on the above developments would be of interest to Canadian accounting and legal practitioners alike who act for individual or corporate non-resident clients. Corporations with U.S. employees working on short-term assignments in Canada would also be interested in this area of taxation. Also, non-resident professional advisors, particularly in the U.S., who need a general reference guide to assess the Canadian tax implications of certain past or proposed transactions, would find the content useful.

Michael I. Atlas, C.A., C.P.A., T.E.P. is an accomplished author and long standing contributor to CCH. He is a Chartered Accountant who practices in Toronto as an independent tax consultant, in connection with a wide-range of domestic and international tax issues. Prior to forming his own practice in 1991, he was the partner in charge of the tax group of one of the 20 largest accounting firms in Canada. His consulting practice places particular emphasis on international and cross-border tax planning matters.

He has also been a frequent speaker on tax matters for many professional and business organizations, including the Canadian Tax Foundation, the Society of Trust and Estate Practitioners, the Institute of Chartered Accountants of Ontario, the Canadian Bar Association, and the Canadian Real Estate Association. Most recently, Michael has made a presentation entitled "Tax Issues for Non-Resident Investors in Canadian Real Estate" as part of "Creative Tax Planning For Real Estate Transactions" for Federated Press on January 26, 2011.

He is also the author of many articles that have appeared in CCH's Tax Topics. His most recent contribution to CCH's Tax Topics was in issue 1986 on April 1, 2010, entitled "Federal Budget Limits Scope of ‘Taxable Canadian Property' and Creates 'FIRPTA Canadian Style'." In addition, he was co-editor (together with David Louis and Brian Nichols) of CCH's "Estate Planning in the Twenty-First Century" series, which appeared bi-monthly in several of its publications. Michael was also co-author of CCH's "Canadian Taxation of Real Estate (4th Ed.)" with Ian MacInnis.

Furthermore, he presented a highly successful webinar for CCH on December 14, 2010 entitled "Offshore Tax Planning: There's Still a Lot Left." Also, on March 2, 2010, together with Robert Misey Jr., he presented an audio seminar for CCH's U.S. affiliate entitled "Canada–U.S. Cross-Border Issues and Strategies."

Michael is a graduate of the University of Texas at Austin and a member of the Institute of Chartered Accountants of Ontario. In addition, he is a U.S.-Certified Public Accountant (Illinois).