The “digital economy” is now worth equivalent to ~15% of global GDP according to the World Bank, and so it is little surprise that its rise has sparked global debate - the most critical of which is the discussion regarding the most appropriate, fair, and efficient way of taxing so-called “digital services” which is […]
Monthly Archives: January 2021
"Characterization", "Unbundling" and the Nature of "The Transaction"
On January 22, 2021, the Federal Court of Appeal delivered its decision in a GST/HST case concerning whether certain fees paid by the Canadian Imperial Bank of Commerce were for "financial" or "administrative" services (Canadian Imperial Bank of Commerce v. The Queen, 2021 FCA 10). The former, "financial services" are exempt from the GST/HST, […]
An Examination of Quebec’s Evolving Patent Box Regime and the OECD’s BEPS Action Plan
Throughout the ongoing review, orchestrated by the Organisation for Economic Co-operation and Development, of the measurement and allocation of international income, the significance of manifestations of “intangibles” – intangible property in the legal sense but also features of the uniqueness of multinational enterprises and their products and services – have been at the forefront. […]
Joint Tax Filing for Spouses
A threshold issue for the design of any tax system is the taxing unit. In Canada our taxing unit for personal taxation is and has always been the individual. The Carter Commission recommended we change the taxing unit to families (spouses and their dependent children) on the grounds that families constitute the basic economic […]
A One-Off Wealth Tax for the United Kingdom (and Canada)?
The Wealth Tax Commission recommended a one-off (as opposed to an annual) wealth tax for the United Kingdom (UK) in a report released on December 9, 2020 (see A Wealth Tax for the UK). The main rationales are to raise tax revenues to address the financial pressures owing to the COVID-19 pandemic, and to reduce inequality […]
Professor Jinyan Li's Commentary on the Pillar One Blueprint Published by OECD - Access Here
The OECD/G20 invited comments from the public on the Pillar One Blueprint and Pillar Two Blueprint, which were both published on October 12th, 2020. Pillar One is about allocating more taxing rights to market jurisdictions in respect of income derived from automated digital services and consumer facing businesses. It is achieved through a new […]