Article 26A - Assistance and Collection

Cases

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

One of the challenges brought by the appellant to the Canadian FATCA legislation (i.e., the Canada-United States Enhanced Tax Information Exchange...

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Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Hansard, explanatory notes, etc. regard to object rather than political statements 55
Tax Topics - Treaties - Income Tax Conventions - Article 25 FATCA requirements were reciprocal and were primarily imposed on financial institutions 182
Tax Topics - Treaties - Income Tax Conventions - Article 27 FATCA information exchanged automatically irrespective of any substantive U.S. tax liability was "relevant" to U.S. tax administration 387

Chua v. MNR, 2000 DTC 6527 (FCTD)

Article XXVI A of the Canada-U.S. Convention was contrary to section 15 of the Charter in light of the citizenship preference contained in...

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See Also

Retfalvi v. USA (2019), No. 18-2158 (U.S.C.A., 4th Circuit)

The appellant (Retfalvi) became a U.S. citizen in 2010 and also was reassessed in 2010 by CRA respecting gains on two Canadian condo sales...

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Ben Nevis (Holdings) Ltd. v. Revenue and Customs Commissioners, [2013] BTC 485, [2013] EWCA Civ 578

The most recent Income Tax Convention between the U.K. and South Africa had entered into force on 17 December 2002, and a Protocol providing for...

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Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Retroactivity/Retrospectivity creation of new collection right did not entail retrospectivity 182
Tax Topics - Treaties - Income Tax Conventions Vienna convention approach applies to non-signatories 207
Tax Topics - Statutory Interpretation - Revenue Rule 124

Administrative Policy

25 July 2012 External T.I. 2011-0427221E5 - FBAR penalties

Penalties that the US collects for failure to report Foreign Bank and Financial Accounts information under form TD F90-22.1 ("FBAR penalties") are...

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Articles

Wolfe D. Goodman, "When can the CCRA enforce a U.S. tax liability under Article XXVI-A of the Convention?", Goodman on Estate Planning, Vol. IX, no. 3, p. 716.

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