Canadian Tax Journal/Revue fiscale canadienne最新文献_第4页

Current Tax Reading 当前税务阅读

Canadian Tax Journal/Revue fiscale canadienne Pub Date : 2023-04-01 DOI: 10.32721/ctj.2023.71.1.ctr

Jinyan Li, A. Macnaughton

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"Tax-Free": The Effect of a Heuristic Cue on the Choice Between a TFSA and an RRSP “免税”:启发式提示对TFSA和RRSP选择的影响

Canadian Tax Journal/Revue fiscale canadienne Pub Date : 2023-04-01 DOI: 10.32721/ctj.2023.71.1.berger

L. Berger, Jonathan Farrar, Ruth Pogacar, Lu Y. Zhang

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Policy Forum: The Income Taxation of Crypto Contracts 政策论坛:加密合约的所得税

Canadian Tax Journal/Revue fiscale canadienne Pub Date : 2023-04-01 DOI: 10.32721/ctj.2023.71.1.pf.romano

Colin Romano

{"title":"Policy Forum: The Income Taxation of Crypto Contracts","authors":"Colin Romano","doi":"10.32721/ctj.2023.71.1.pf.romano","DOIUrl":"https://doi.org/10.32721/ctj.2023.71.1.pf.romano","url":null,"abstract":"Current Canada Revenue Agency (CRA) guidance suggests that cryptoassets (such as bitcoin) should generally be taxed as commodities for the purposes of the Income Tax Act. However, recent changes in the regulation of entities that facilitate the purchase and sale of cryptoassets (crypto trading platforms) under securities law have introduced new ways of understanding transactions involving cryptoassets. Many crypto trading platforms hold cryptoassets on behalf of users rather than delivering the cryptoassets directly to them, and the Canadian Securities Administrators has taken the position that this relationship among crypto trading platforms and their users itself constitutes a security. To date, there has been no guidance from the CRA relating to the taxation of these securities, which are known as \"crypto contracts.\" This article considers potential income tax implications arising from the existence of crypto contracts by exploring how income taxation would differ for users of crypto trading platforms if they were taxed on crypto contracts rather than cryptoassets. Specifically, the article considers the treatment of transactions as being on income or capital account, the availability of elections to treat transactions on capital account, the applicability of section 49.1 of the Income Tax Act, and the income taxation of staking rewards earned through crypto trading platforms. Rather than offering conclusions on these topics, this article aims to provide a framework for thinking about crypto contracts from a Canadian income tax perspective and to provoke further thought from Canadian tax professionals.","PeriodicalId":375948,"journal":{"name":"Canadian Tax Journal/Revue fiscale canadienne","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2023-04-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"114936583","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

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Planification fiscale personnelle : Les crédits pour impôt étranger pour les contribuables ayant un revenu d'emploi transfrontalier 个人税务筹划:跨境就业收入纳税人的外国税收抵免

Canadian Tax Journal/Revue fiscale canadienne Pub Date : 2023-04-01 DOI: 10.32721/ctj.2023.71.1.pfp

Lee Mi, Shivani Joshi

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Policy Forum: Editors' Introduction—The Tax Treatment of Cryptoassets 政策论坛:编辑介绍-加密资产的税收处理

Canadian Tax Journal/Revue fiscale canadienne Pub Date : 2023-04-01 DOI: 10.32721/ctj.2023.71.1.pf.editors

A. Macnaughton, Kevin Milligan, Daniel Sandler, Frances R. Woolley

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Policy Forum: Canada's Proposed Cryptoasset Legislation 政策论坛:加拿大拟议的加密资产立法

Canadian Tax Journal/Revue fiscale canadienne Pub Date : 2023-04-01 DOI: 10.32721/ctj.2023.71.1.pf.kreklewetz

Robert G. Kreklewetz, Laura J. Burlock

{"title":"Policy Forum: Canada's Proposed Cryptoasset Legislation","authors":"Robert G. Kreklewetz, Laura J. Burlock","doi":"10.32721/ctj.2023.71.1.pf.kreklewetz","DOIUrl":"https://doi.org/10.32721/ctj.2023.71.1.pf.kreklewetz","url":null,"abstract":"Cryptoasset miners verify and record transactions, maintaining the integrity and security of the blockchain network. The Department of Finance (\"Finance\") has recently proposed new Excise Tax Act (ETA) provisions regarding the goods and services tax (GST)/harmonized sales tax (HST) treatment of crypto mining. Under these proposed provisions, crypto mining activities provided to anonymous recipients will not be subject to GST/HST, but the crypto miners performing these activities will also not be eligible to recover any GST/HST paid on their business inputs (and thus will be forced to bear the brunt of the tax themselves). We believe that Finance's decision to tax what it can identify—the business inputs of Canadian crypto miners—is a roughly balanced but reasonable approach. Although Finance might be legitimately criticized as departing from Canada's decision to eliminate the cascading of tax found in the former origin-based federal sales tax, it seems impossible to administer a destination-based transactional tax such as the GST/HST when faced with \"anonymous\" recipients (the users of the crypto miner's services). Finance appears to have minimized the cascading of tax by including a carve-out for identifiable recipients of a crypto miner's services, allowing the regular zero-rating rules in the ETA to apply in limited circumstances. In the face of utter uncertainty, Finance's reactive approach is likely the best that it can do. Given the rapid evolution and inherent decentralization of the crypto space, a more broadly based proactive approach would seem imprudent at this time.","PeriodicalId":375948,"journal":{"name":"Canadian Tax Journal/Revue fiscale canadienne","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2023-04-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"123743995","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

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Implementing Pillar Two: Potential Conflicts with Investment Treaties 实施第二支柱:与投资条约的潜在冲突

Canadian Tax Journal/Revue fiscale canadienne Pub Date : 2023-04-01 DOI: 10.32721/ctj.2023.71.1.sym.brown

Catherine A. Brown, E. Whitsitt

{"title":"Implementing Pillar Two: Potential Conflicts with Investment Treaties","authors":"Catherine A. Brown, E. Whitsitt","doi":"10.32721/ctj.2023.71.1.sym.brown","DOIUrl":"https://doi.org/10.32721/ctj.2023.71.1.sym.brown","url":null,"abstract":"A key objective of pillar two is to coordinate a minimum 15 percent tax on the GloBE income of certain in-scope multinational enterprises. This objective has been driven by the Organisation for Economic Co-operation and Development and focuses on global cooperation and model rules to calculate and collect the proposed tax. Tax is also a key driver in investment decisions. By design or default, the pillar two rules will clash with the typical tax incentives offered by countries to attract foreign direct investment, including tax holidays, lower tax rates, exemptions, and accelerated depreciation regimes. Often these tax incentives are offered in investment treaties. These agreements offer a win-win solution in that they set out the minimum protections that investors may rely on when making an investment in the host state, backed up by the direct remedy of binding international arbitration if those protections are not provided. For the host state, the protections provided by an investment treaty encourage inbound cash flows, and for the investor's home state, they offer the hope of repatriated profits. Although no precise numbers can be offered, clearly the tax benefits provided by investment treaties will be affected by the pillar two rules. This paper outlines some of the potential conflicts between pillar two requirements and the protections provided in investment treaties. It also offers some preliminary solutions.","PeriodicalId":375948,"journal":{"name":"Canadian Tax Journal/Revue fiscale canadienne","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2023-04-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"127800715","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

引用次数: 0

Canadian QDMTT Challenges 加拿大QDMTT挑战

Canadian Tax Journal/Revue fiscale canadienne Pub Date : 2023-04-01 DOI: 10.32721/ctj.2023.71.1.sym.li.etal

Jinyan Li, Angelo Nikolakakis, Jean-Pierre Vidal

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Finances of the Nation: Survey of Provincial and Territorial Budgets, 2022-23 国家财政:各省和地方预算调查，2022-23

Canadian Tax Journal/Revue fiscale canadienne Pub Date : 2023-04-01 DOI: 10.32721/ctj.2023.71.1.fon

D. Lin

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Corporate Tax Planning: ESG and Corporate Tax Planning 企业税收筹划:ESG与企业税收筹划

Canadian Tax Journal/Revue fiscale canadienne Pub Date : 2023-04-01 DOI: 10.32721/ctj.2023.71.1.ctp

Katerina Ignatova, Christopher J. Steeves

{"title":"Corporate Tax Planning: ESG and Corporate Tax Planning","authors":"Katerina Ignatova, Christopher J. Steeves","doi":"10.32721/ctj.2023.71.1.ctp","DOIUrl":"https://doi.org/10.32721/ctj.2023.71.1.ctp","url":null,"abstract":"Environmental, social, and governance (ESG) is a framework for considering certain risks and opportunities applicable to a company. Investors, and increasingly regulators, are requiring disclosure of certain ESG-related metrics and data. Some of these data reflect the externalities that a company creates with respect to the environment and to society. Investors, and potentially regulators and governments, can use these data to evaluate the company and price negative externalities. Being prepared and proactive will allow a company to develop a tax strategy that is consistent with its larger ESG goals. Globally, there is an increasing obligation for companies to publish a tax strategy, as well as to disclose uncertain tax positions and aggressive tax planning to the tax authorities and the public. This trend is also making its way into Canada, albeit at a slower pace. As the Canadian government and investors move toward pricing negative externalities using ESG metrics, it is crucial that Canadian companies start to consider the role of ESG with regard to tax planning, if they have not done so already. Canadian companies should also consider how their tax strategy will be perceived by the company's stakeholders, including the public, clients, and employees.","PeriodicalId":375948,"journal":{"name":"Canadian Tax Journal/Revue fiscale canadienne","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2023-04-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"130913682","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

引用次数: 0