Canadian News

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 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 […]

Hiding in Plain Sight? Changes to “Transfer Pricing” and the GAAR

  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 […]

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 […]