A Canadian energy company lost its bid to dismiss a C$32.8 million ($23.5 million) increase to its tax bill over dividends paid out to foreign shareholders.
The Federal Court of Appeal dismissed Husky Energy Inc.’s appeal of a Tax Court of Canada judgment that ruled the payments should be taxed at 15% rather than 5% after discerning which of Canada’s tax treaties—and their corresponding withholding rates—should be applied.
“The Tax Court did not commit the palpable and overriding error asserted by Husky,” Justice Nathalie Goyette wrote on behalf of a three-judge panel in the ruling published Wednesday.
Canada ...
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