David Chodikoff comments on application of provision in U.S.-Canada tax treaty in The Athletic

26 juillet 2024 | David W. Chodikoff | Toronto

( Disponible en anglais seulement )

The Athletic, "‘Anywhere but Canada’: How a tax ruling could hobble pro teams north of the border"

David Chodikoff features in an article from The Athletic on how professional athletes are taxed in Canada and the interpretation of a provision in the U.S.-Canada tax treaty that would allow them to pay a lower tax rate on an initial signing bonus. The article centres around a Notice of Appeal filed in the Tax Court of Canada by Toronto Maple Leafs player John Tavares:

So the argument is really over the U.S.-Canada tax treaty and its application — and whether it applies to Tavares’ circumstances, says Chodikoff.

If the CRA’s challenge in the Tavares case is successful, it will reframe how the provision for bonuses is applied more widely — and that’s likely why the Canadian tax authority is going after this case, Chodikoff says.

“I think the biggest reason they’re taking a run at this is the implications it could have on a much broader basis for other taxpayers,” Chodikoff says.

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