Canada: Tax

The perception that Internal Revenue Service enforcement is stronger than Canada Revenue Agency enforcement is common among taxpayers and advisors, particularly in cross-border contexts.

Permanent establishment Canada analysis has become increasingly complex due to the OECD’s 2025 remote work guidance. Remote work permanent establishment Canada risk is now a central concern for businesses operating across borders and provinces.

Colombian superstar Shakira has secured an important win against Spanish tax authorities. Spain’s High Court cleared her of tax fraud charges for the 2011 tax year and directed the government to repay over US$64 million in fines and interest.

Probate is the legal process through which a deceased person's will is validated by the courts, and the administration of his or her estate is carried out according to the terms of the will.

Recent amendments to Canada's Income Tax Act have extended the post-mortem loss carryback election from one to three taxation years, providing estate administrators significantly more time to implement tax planning strategies.

Canadians who own US property, hold American investments, or have family members with US citizenship face a complex web of estate tax obligations spanning two countries. Without proper coordination, your heirs could face double taxation, frozen assets during lengthy Florida probate proceedings, or unexpected tax bills that consume a significant portion of their inheritance.

The Canada Revenue Agency (CRA) has significantly expanded its cryptocurrency tax enforcement efforts in recent years.

Corporations are treated as distinct legal persons, separate from their shareholders, directors, and officers.

Foreign currency transactions are now a permanent feature of Canadian tax planning for corporations, entrepreneurs, investors, and cryptocurrency participants.

Business leaders operating across borders frequently compare the Canada Revenue Agency (CRA) and the Internal Revenue Service (IRS) when evaluating tax compliance risk, administrative efficiency, and audit exposure.

Canada’s new transfer pricing rules are in effect for tax years beginning after the 2025 federal budget (i.e., 2026 for calendar year taxpayers). It will be many years before the courts weigh in on the impact of the amendments, but the time for multinationals to ready themselves for CRA audit scrutiny is now. Below, we outline the key changes in the amendments and the practical steps that taxpayers can take today.

On March 26, 2026, Canada's new transfer pricing rules received royal assent and will have a significant impact on multi-national enterprises (MNEs) in life sciences industries.