Rejunvenating the Blog

This blog has been very quiet, not, however, for want of interesting developments to note.  An effort will be made at least weekly to note and comment on developments in Canada and elsewhere as the Fall term at the law school resumes.  Ideas and contributions to the blog, and certainly comments about posted items, are […]

The Supreme Court of Canada Decides Loblaw Financial Holdings Inc. - “President’s Choice” Brands the “Foreign Affiliate” Regime - Updated

  *This is an updated post that reflects helpful comments on the earlier post provided by a number of friends and colleagues who share my interest in this case and indeed the law more broadly. "Loblaws" is an established Canadian grocer. It markets a comprehensive line of high quality products and services, including financial services, […]

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 […]