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 […]
Monthly Archives: June 2021
Richard Bird - Remembering a Canadian Taxation Giant
Richard Bird passed away suddenly on Wednesday June 9, 2021. It's hard to imagine. He has been in my professional consciousness for as long as I've had one and our collective consciousness for much longer as a leader in taxation and public finance, in Canada certainly but also in the world. There are few […]
More on "Minimum Tax", BEPS, the Pillars, CFC Rules and Trade Law
Thinking Beyond the Limits of Immediate Perception It is sometimes revealing to step back from the assumptions and presumptions of any discussion to appreciate its essence. This is sometimes called "thinking outside the box". There are other euphemisms directed to blinkered thinking, for example, not seeing the forest for the trees. I had a […]
The G7 Finance Ministers and Central Bank Governors “Agree” to Global Tax “Changes”: “What You See … and What You Don’t”
Reports of a Global Minimum Tax It is much reported today that the G7 Finance Ministers agreed to implement a global corporate minimum tax. The Communiqué and a supporting commitment to developing beneficial ownership registries can be found by clicking the hyperlinks. (Also see here an html-friendly version of the Communiqué). This note does […]