Faced with significant government spending to tackle Covid-19 in the UK, the UK Wealth Tax Commission was set up to explore the desirability and feasibility of a wealth tax. The final report was issued on 9th December 2020.[1] The Evidence Papers are available here.[2] The proposal was to implement a one-off wealth tax of […]
International News
Blueprints for A Parallel Tax Universe
Blueprints for a new international tax regime fit for the digitalizing global economy were published by the OECD/G20 Inclusive Framework on BEPS (the Inclusive Framework) on October 12, 2020. Because the new regime represents “global law” and introduces concepts and rules not found in existing domestic and treaty laws, a parallel tax universe is […]
Are Gig Workers Independent Contractors or Employees?
On November 3, 2020, Californians approved Proposition 22 exempting gig companies from legislation classifying their workers as employees. The ballot initiative was the most expensive in the State’s history with Uber and its allies spending over $200 million to achieve 58% of the vote. It undermines Assembly Bill 5, which presumes workers to be […]
Things Go Better with Coca-Cola? Well, Maybe Not Always
On Wednesday November 18, 2020, the United States Tax Court, via the pen of a very able Judge, issued the decision in a very important transfer pricing case, The Coca-Cola Company & Subsidiaries, Petitioner v. Commissioner of Internal Revenue, Respondent, 155 T.C. No. 10. Caution is always required in reading the tax decisions of […]
The Supreme Court's Accumulating Tax Brief - To What End?
A question that has lingered through the Summer and into the Fall has been answered in the last couple of days. Leave of the Supreme Court of Canada has been sought by the tax authorities to appeal the Federal Court of Appeal's early Summer decision in Cameco. If the Supreme Court grants leave, it […]
Resurrecting the Advisory Panel’s Recommendation for a Full Exemption System
For some time there has been debate about our current system of providing double tax relief for foreign-source active business income earned by Canadian corporations indirectly through foreign affiliates. In the 1970’s the drafters of the Act chose a hybrid mechanism using both the exemption and credit systems. But this requires surplus account tracking, […]
Week in Review - October 18, 2020
Home Office Tax Deductions Simplified - More Changes May Come Yet: The Canada Revenue Agency is making changes to the Form T2200 - which is the form the CRA requires employers to sign confirming an employee’s eligibility to claim expenses - in order to simply home office tax deductions, in response to changing work […]
The Latest Developments in the BEPS 2.0 Project
On October 12, 2020, the Organization for Economic Co-operation and Development (OECD) transmitted a webcast to inform the latest developments regarding the work that the OECD/G-20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) has been doing to address the challenges arising from the digitalization of the economy (the so-called “BEPS 2.0”). The project builds […]
Week in Review - October 2, 2020
Federal Government Quietly Promises Automatic Tax Returns in Speech from the Throne: Prime Minister Justin Trudeau's federal government is reportedly set to introduce an automatic tax return system for simple federal tax returns, which could revolutionize access to tax return benefits for many Canadians who do not file returns every year. A study from […]
Week in Review - September 25, 2020
Supreme Court of Canada Reserves Judgement After Two Days of Hearings in "Carbon Tax" Dispute: Following two days of hearings on Tuesday and Wednesday, the Supreme Court of Canada chose to reserve judgement in the critical "carbon tax" series of cases, which unites three separate appeals from the Provinces of Alberta, Saskatchewan, and Ontario, […]