The international tax community is consumed with re-evaluating the utility and adequacy of typical markers of international tax jurisdiction, associated among others with the tax treaty notion of “permanent establishment”. In this context, a PE, as it is known, is a description of what is considered to be a sufficient intensity of business presence […]
International News
Is a First Nation Sovereign if the Canada Revenue Agency Enforces its Tax Laws?
A distinct “order” of government The 1996 Royal Commission (Commission) on Aboriginal Peoples[1] gathered information about Aboriginal perspectives on sovereignty, self-determination, and self-government. It also examined the legal and political principles that underlie and inform the emergence of an Aboriginal order of government [author’s emphasis] in Canada. Emanating from these two information sources, the […]
Week in Review - July 11, 2020
Federal Government Reports $343 Billion Budget Deficit - Biggest Since Second World War: Minister of Finance Bill Morneau revealed on Wednesday that the federal budget is expected to post a deficit of $343 billion - an unprecedented budgetary shortfall, attributed mostly to the government's response measures to the COVID-19 pandemic. Similar levels of spending […]
OECD Releases New Corporate Tax Statistics - Including Data on Nearly 4000 MNE's
The Organisation for Economic Co-operation and Development (OECD) released their annual Corporate Tax Statistics publication yesterday (July 8), which includes aggregated information on the global tax and economic activities of nearly 4,000 multinational enterprise (MNE) groups headquartered in 26 jurisdictions and operating across more than 100 jurisdictions worldwide. This data released on MNE's by […]
Corporate Tax Reform for Developing Countries
Revenues from the corporate income tax are especially important to developing countries, which, largely because of their low per capita incomes, have greater difficulty than wealthier countries in collecting broad-based taxes like the personal income tax and the VAT. Much of the corporate tax revenue of developing countries comes from multinational companies which have […]
“Think About the Why of Spending Before the How of Paying” and Remember, “Luck Has a Lot to Do With It” – Ed Kleinbard’s Legacy
This is not an obituary, at least it is not meant to be. However, I suppose it could be. Ed Kleinbard is one of the most profound, straightforward and intellectually honest “thinkers” in taxation of his and our time – and I would say, given his experience with advising on, crafting and commenting on […]
Week in Review - July 3, 2020
OECD Publishes Reporting Framework for the Gig and Sharing Economy: Today (Friday, July 3rd), the OECD published model rules that governments may adopt which requires platform operators such as Uber and AirBnB to collect data on their sellers and report that information to tax administrations for compliance purposes. The rules are intended to provide a […]
Week in Review - June 26, 2020
European Bloc Suggests Phased Approach to Global "Digital Tax" Negotiations: Following reports last week that the United States was withdrawing from international discussions regarding a potential "digital tax" deal, European powers including the United Kingdom, France, Spain, and Italy have suggested a slower, "phased" approach to negotiations in a letter sent to US Secretary […]
Week in Review - June 19, 2020
The United States Withdraws From Global Digital Tax Negotiations: This week in tax news was defined by the US government's decision to withdraw from multilateral international discussions regarding a potential "digital tax" deal, which could result in a wave of new taxes on US tech giants like Amazon, Alphabet Inc. (Google), and Facebook. US […]
Paying for COVID Relief and the State of Corporate Taxation
One of Canada’s most prolific commentators on tax matters in Canada, particularly international tax developments as Canada is affected by them, is Nat Boidman, who practices at Davies Ward Phillips & Vineberg LLP in their Montreal office. Nat’s comments regularly are a catalyst for hard thinking about tax matters. In a recent Letter to […]