Translation of "Décision anticipée en matière fiscale " (French → English) :

certainty and predictability – e.g. a transparent, efficient appeals process, reliable advance rulings on tariff classifications.

the decision on supervision measures relates, in the cases referred to in Article 14(3) and, where the executing State has made a declaration under Article 14(4), in the cases referred to in Article 14(1), to an act which would not constitute an offence under the law of the executing State; in tax, customs and currency matters, however, execution of the decision may not be refused on the grounds that the law of the executing State does not prescribe any taxes of the same kind or does not contain any tax, customs or currency provisions of the same kind as the law of the issuing State.

Q-21 — Mr. Rajotte (Edmonton Southwest) — Since 1993, and for each fiscal year since, with respect to advance tax rulings made by the government: (a) what departments make advance tax rulings; (b) which departments make policy on advance tax rulings; (c) what advance tax rulings were made as a result of a submission by the holdings of the “blind trust” of the Prime Minister; (d) what was the name of the company; (e) what was the value of the tax ruling; (f) did these ruling involve countries other than Canada; and (g) was there ...[+++]any correspondence between the Minister of Finance and/or anyone in his office concerning these rulings?

—the date of entry into force of an agreement between the European Community, following a unanimous decision of the Council, and the last of the Swiss Confederation, the Principality of Liechtenstein, the Republic of San Marino, the Principality of Monaco and the Principality of Andorra, providing for the exchange of information upon request as defined in the OECD Model Agreement on Exchange of Information on Tax Matters released on 18 April 2002 (hereinafter the ‘OECD Model Agreement’) with respect to interest payments, as defined in this Directive, made by paying agents established within their respective territories to beneficial owne ...[+++]rs resident in the territory to which the Directive applies, in addition to the simultaneous application by those same countries of a withholding tax on such payments at the rate defined for the corresponding periods referred to in Article 11(1),

On SOR/98-221 Order Amending the Advance Income Tax Ruling Fees Order; SOR/90-234 Advance Income Tax Ruling Fees Order; and SOR/92-114 Advance Income Tax Ruling Fees Order, amendment (before the committee on March 24, 1994 and May 30, 1996), It was agreed, That the files be closed.

The U.S. Internal Revenue Service issued an advance tax ruling to Kiewit confirming that indeed the spinoff was tax free to its U.S. employee shareholders and was not tax motivated.