The international tax community is consumed with re-evaluating the utility and adequacy of typical markers of international tax jurisdiction, associated among others with the tax treaty notion of “permanent establishment”. In this context, a PE, as it is known, is a description of what is considered to be a sufficient intensity of business presence […]
Daily Archives: July 21, 2020
Is a First Nation Sovereign if the Canada Revenue Agency Enforces its Tax Laws?
A distinct “order” of government The 1996 Royal Commission (Commission) on Aboriginal Peoples[1] gathered information about Aboriginal perspectives on sovereignty, self-determination, and self-government. It also examined the legal and political principles that underlie and inform the emergence of an Aboriginal order of government [author’s emphasis] in Canada. Emanating from these two information sources, the […]
Prelude to Saro Persaud and "First Nations Taxation"
In the following post, Saro Persaud examines “international” taxation in Canada with reference to First Nations among other nations in Canada and in that connection how First Nations taxation is administered. The situation of “first nations” in relation to other “nations” within Canada reflects parallels unconstrained by the typical domestic Canadian political and constitutional […]