Patrick Marley

Canadian mandatory disclosure rules update: implementing bill and explanatory notes

Significant development for Canada’s income tax mandatory disclosure rules: implementing bill and explanatory notes released

OECD releases guidance for Pillar Two, including GILTI coexistence and QDMTT design

The OECD released administrative guidance for implementing the global minimum tax under Pillar Two, including GILTI coexistence and QDMTT design.

Canada proposes significant tax amendments to align with OECD BEPS recommendations

In 2022, the federal government released draft legislation to adopt many of the OECD’s BEPS recommendations...

OECD releases three Pillar Two documents, including guidance on safe harbours

New documents include guidance on safe harbours and penalty relief in respect of the model Global Anti-Base Erosion Rules, plus public consultation...

Canadian anti-hybrid tax legislation released in draft

On April 29, 2022, the Department of Finance released the first of two packages of draft legislation to implement its proposals to eliminate the tax...

OECD releases model rules for global minimum tax

The OECD released model rules for the proposed global minimum tax under Pillar Two of the OECD/G20 Inclusive Framework.

Tax planning developments: Important international tax changes

In 2021, a number of significant changes were proposed for international taxation in Canada. Find out more about what changes were introduce in 2021...