Recently, the Federal Court of Appeal addressed the nature of a government instrumentality. This classification, expressed in various ways in the Income Tax Act, is important because, broadly, governments generally do not tax each other. This is notable in various paragraphs of section 149 of the Act, and is a longstanding exception to the […]
All posts by jswilkie
Thinking About Collective Wealth and Consumption
Most tax issues elicit a conversation, particularly when shed of the "technical" but for many arcane language of tax specialists, they are seen in the light of their impact on what broadly we might call "civil society" but more generally might be described as how we respond to critical questions about how we live […]
“Diving” into Tax Treaty Issues: The Deep End or the Shallow End?
The United Kingdom Supreme Court’s recent decision in Fowler v Commissioners for Her Majesty’s Revenue and Customs, [2020] UKSC 22, is likely to be seen as an important international tax case and, to that end but possibly without as much justification as discussion in the tax community may make it seem, as a “tax […]
Accessible Justice in Tax Matters
The COVID-19 Pandemic and the institutional responses to it by governments and their instrumentalities offer opportunities to accelerate change and novelty in the way in which citizens and business enterprises interact with authorities including tax authorities. An outcome may be to streamline the legal system in ways that were only "ideas" until recently and […]
We are Live! Welcome to the Tax at Osgoode Hall Law School Blog - A Forum for Informed and Informative Tax Conversation
Welcome. The title of this post says it all. Tax at Osgoode Hall Law School - a forum for tax "conversation" orchestrated by the tax community at Osgoode Hall Law School - is up and running. I am Professor Scott Wilkie, a member of the Osgoode Hall Law School faculty and principal curator of […]