A word from Professor Scott Wilkie: Professor Jinyan Li and Ms. Sophie Chatel, both drawing on their expertise and experience in international tax, have recently co-written this article published by the International Bureau of Fiscal Documentation in the Bulletin for International Taxation, which is now freely available and can be accessed by clicking here. […]
International News
Perspective Matters: One Country’s “Offshore” is Other Countries’ “Onshore”
Perspective Matters: One Country’s “Offshore” is Other Countries’ “Onshore” This post just as easily could have been entitled, “The Realpolitik of International Tax and Fiscal Relations” or, “Multilateralism: Be Careful What You Wish For”. Or, reflecting how these comments conclude, “As for Position in Art, Here Fiscal Position Matters.” Global Minimum Tax and […]
Trading Options in a TFSA: The Blurred Line Between a Permitted Use and “Carrying on a Business”
The pandemic has resulted in accelerated participation in retail trading in the stock market. Retail investors accounted for 45% of total equity trades in January 2021 on the Toronto Stock Exchange, which is an increase from 35% in 2019.[1] Option trading has also become more popular for retail investors; data from the Chicago Board […]
The Cameco Transfer Pricing Appeal Ends Today
The Cameco Corporation transfer pricing decisions of the Tax Court of Canada and the Federal Court of Appeal are seminal, not just for Canadian taxation but internationally. The case wrestles with the interaction of private law constructions that lie at the heart of corporate and business organization, on the one hand, and the international […]
Transfer Pricing Conference Day 1 Highlight: Discussions on Recharacterization Rules
On Wednesday, February 3, 2021, the Canadian Tax Foundation hosted its Day 1 Program of the Transfer Pricing Conference virtually. Dialogues between the tax authorities and the private practice sector went back and forth on four panels. The highlight of the discussions was the recharacterization rules in paragraphs 247(2)(b) and (d) of the ITA. […]
Minister Freeland Anticipates Unilateral Action on “Digital Services Taxes”
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 […]
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. […]
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 […]
COVID and "Infrastructure"
The recent appointment of Michael Sabia as the new Deputy Minister of Finance invites reflection on what his personal experience and evident policy inclinations might mean for the economic reconstruction necessary to recover from the fiscal strains imposed by the COVID-19 pandemic. In a former government role and evidently in a prior private business […]