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 […]

Repurposing Pillar One into an Incremental Global Tax for Sustainability: A Collective Response to a Global Crisis

  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. […]

The Permissibility of Surplus Stripping

  My Davies tax group colleagues Chris Anderson and Etyan Dishy (both of whom are former Osgoode students of mine!) have published a terrific article in the latest Canadian Tax Journal on “The Permissibility of Surplus Stripping”. The authors begin with a review of the legislative and judicial context surrounding sections 84.1, 212.1 and subsection […]

The 2021 Canadian Federal Budget

  The 2021 Canadian Federal Budget: The Government’s Direction After a long COVID-19 pandemic induced hiatus and occasional less formal economic updates and statements, a Federal Budget was tabled in the House of Commons yesterday, April 19.  Entitled “A Recovery Plan for Jobs, Growth, and Resilience”, it is a lengthy document that no doubt will […]

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 […]

Our Students Make Us Proud - Osgoode Judged the Winner of the 2021 Donald G. H. Bowman National Tax Moot

  The Osgoode Hall Law School Team - Miya Zakharchuk, Portia Biswas, Baiqing Luo, Daniel Mount, and Matt Wilson - were the winners yesterday of the 2021 Donald G. H. Bowman National Tax Moot.  This is a remarkable, notable success for them and for the Osgoode community which they so ably represented. This Tax Moot […]