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 […]

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. […]

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.  […]

Joint Tax Filing for Spouses

  A threshold issue for the design of any tax system is the taxing unit.  In Canada our taxing unit for personal taxation is and has always been the individual. The Carter Commission recommended we change the taxing unit to families (spouses and their dependent children) on the grounds that families constitute the basic economic […]

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 […]