An End to Uncertainty – Crown Will Not Appeal Taxpayer’s Victory in
Prévost Car
Date:
April 14 2009
The taxpayer's victory is now complete and multinational enterprises around the world can breath a little easier - the Crown will not be seeking leave to appeal the Federal Court of Appeal's decision in The Queen v. Prévost Car, Inc. to the Supreme Court of Canada. The Federal Court of Appeal's decision in this case now firmly reflects the proper interpretation of the term "beneficial owner" for purposes of determining a non-resident's entitlement to reduced rates of Canadian withholding tax on interest, dividends and royalties pursuant to a Canadian income tax convention.
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