The Taxpayer is Successful Today at the Supreme Court in the Important Alta Energy "Treaty Shopping" Case - Updated

  What is "treaty shopping"? It is an often used and disparaging phrase in international tax practice. But, in fact few really know what it means, contrasted with what for various reasons they want it to mean. Today, we have a much better idea of what "treaty shopping" is not. We are also reminded in […]

Professor Scott Wilkie Comments on the Latest OECD "Pillars" Developments

It is well known that the Organisation for Economic Co-operation and Development (OECD) and the Inclusive Framework of approximately 140 countries that the OECD has organized, have been engaged in developing recommendations to rejig the "rules" and conventions by which countries assume and allocate among each other, taxing rights.   The catalyst, of course, and […]

Professor Jinyan Li Speaks About China's Ascendancy in International Tax

Recently, Professor Jinyan Li Spoke about the deveolpment and influence of Chinese tax policy in relation to global economic and tax developments in an inverview hosted by the International Bureau of Fiscal Documentation, conducted by Professor Johann Hattingh of the University of Cape Town, South Africa.  Professor Li's comments are important, coming as they do […]

Hiding in Plain Sight? Changes to “Transfer Pricing” and the GAAR

  Abstract Drawing on comparative references to transfer pricing legislation in the United Kingdom and Australia and on the legislative “General Anti-Avoidance Rule” in the United Kingdom, these comments probe to identify and suggest responses to the underlying “problem” that pervades transfer pricing and Canadian GAAR jurisprudence but is, it seems, either thought or thought […]