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Effective Responses to Aggressive Tax Planning: What Canada Can Learn from Other Jurisdictions (2009) by Gilles N. Larin and Robert Duong with a contribution from Marie Jacques, TP 112

(Available July 2009)

This study presents an analysis of tools used in the United States, the United Kingdom, Australia, and the European Union to counter aggressive tax planning. The authors conclude that Canada should consider adopting some of these tools, consistent with the principles of equity, predictability, and uniformity in the administration of the tax law.

In protecting the integrity of a tax system, no single tool is adequate. Only an array of tools can succeed in clarifying the grey areas that create opportunities to engage in abusive tax-avoidance schemes, and at the same time significantly change the assessment of risk by taxpayers and their advisers.

Establishing a predictable and equitable dividing line between legitimate and abusive tax-planning schemes is crucial. Canada’s general anti-avoidance rule (GAAR) is a useful tool, but it can clearly be improved. Experience abroad suggests that the GAAR should take into account the economic reality of tax operations. In addition, the GAAR should be bolstered by the adoption of other anti-avoidance measures that have proved successful in other jurisdictions.

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Finances of the Nation 2008 by Karin Treff and Deborah Ort

A review of expenditures and revenues of the federal, provincial, and local governments of Canada

The Canadian Tax Foundation’s annual publication examining the tax and spending activities of Canada’s three levels of government.

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Reforming Canada's International Tax System: Toward Coherence and Simplicity (2009) by Brian J. Arnold, Tax Paper 111

This book deals with the international aspects of Canada's income tax system, focusing primarily on direct investment by corporations. It identifies deficiencies in the current rules, presents and analyzes options for reform, and makes recommendations to improve the system.

The book examines the taxation of foreign-source income of Canadian residents and the taxation of Canadian-source income of non-residents. It also analyzes the process for formulating international tax policy and Canada's tax treaties.

Brian J. Arnold is a consultant with Goodmans LLP, Toronto, and the author of several books and many articles for the Canadian Tax Foundation.

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Financing Education and Training in Canada, Second Edtion by Douglas Auld and Harry Kitchen, Tax Paper 110

In this book, the authors examine several current issues relating to financing education and training in Canada. They address the changes that have occurred in the methods of financing primary and secondary education across Canada and discuss whether these changes have improved the efficiency and equity of education finance at these levels. They also examine the nature of higher education and the progress, if any, that has been made to reduce the average debt burden of college and university students through changes in taxation and student loan plans. And finally, they examine Canada's record of funding employee training in recent years.

The authors address these and other issues, not only providing an update on current financing trends but also highlighting the need for reform where appropriate.

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The Canadian Federal-Provincial Equalization Regime: An Assessment by Alex S. MacNevin, Tax Paper 109

In this book, Alex S. MacNevin examines approaches to interprovincial equalization for Canada. He analyzes the Canadian equalization program in detail, explores the strengths and weaknesses of alternative models, and assesses their comparative strengths and weaknesses. Other topics explored are the conceptual basis for equalization, the measurement of fiscal capacity and expenditure needs, and current controversies related to the Canadian equalization program.

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Venture Capital and Tax Incentives: A Comparative Study of Canada and the United States by Daniel Sandler, Tax Paper 108

Although technological innovation occurs primarily in large corporations, a significant amount of innovation is generated by small and medium-sized enterprises (SMEs), particularly in the high-tech sector. Federal, provincial, and state governments in Canada and the United States have recently focused their attention on SMEs as important engines of economic growth. They have introduced a plethora of measures to increase the supply of venture capital—high-risk equity or near-equity investment in businesses with limited tangible assets but significant growth potential. This book examines government expenditure programs, particularly tax expenditure programs, that target venture capital formation in Canada and the United States in order to determine which government policies best address the market failures that affect the supply of capital to SMEs.

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The Taxation of Business Profits Under Tax Treaties, by Brian J. Arnold, Jacques Sasseville, and Eric M. Zolt, eds., Tax Professional Series

In a global economy dominated by multinational enterprises, one of the most pressing tax issues is how revenue derived from the taxation of business profits should be allocated among competing jurisdictions. At present, this allocation is governed primarily by the provisions of the rapidly expanding network of bilateral tax treaties. This collection of papers by internationally recognized tax-treaty experts examines the most important aspects of the taxation of business profits under tax treaties.

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International Taxation in the Age of Electronic Commerce: A Comparative Study, by Jinyan Li, Tax Professional Series

This comparative study discusses how electronic commerce may be taxed under tax treaties and the domestic law of Canada, China, Hong Kong, Japan, Singapore, and the United States. These jurisdictions were selected for their collective dominance in electronic commerce and their different perspectives on international tax policy. The book also provides a systematic analysis of international tax theories, policy objectives, and fundamental concepts and principles, and examines the extent to which they remain valid in the digital age.

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Canadian Tax Foundation Style Guide, 4th Edition

Tax writing poses unique challlenges to authors and editors. The fourth edition of the Canadian Tax Foundation Style Guide provides guidance and examples in matters of editorial style, case ans statute citation (including the citation of electronic documents and the emerging neutral citation standard), and usage. This style guide will be of interest and use to all who must communicate in the language of tax and policy analysis.

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Municipal Revenue and Expenditure Issues in Canada by Harry M. Kitchen, Tax Paper 107

Because the municipal sector's growing importance has failed to inspire a corresponding increase in the study of municipal finance, municipal officials often lack the information they need to deal appropriately with the issues that face them. This book attempts to help remedy this situation. It examines current practices in municipal finance, in an analytical framework that emphasizes efficiency, accountability, transparency, and fairness, and suggests some possible courses of fiscal innovation and reform at the level of local government.

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Taxes and the Canadian Underground Economy, by David E.A. Giles and Lindsay M. Tedds, Tax Paper 106

The level of underground economic activity in Canada is comparable to the level in similar economies. Moreover, the Canadian hidden economy has been growing relative to the measured economy. In this book, the authors appraise various techniques that economists have used to measure the underground economies in Canada and other countries, and they offer new estimates of underground activity in Canada. After examining the relation between taxes and hidden economic activity, they present new empirical evidence about the effect on Canada's underground economy of changes in the tax burden and the tax mix. The book balances general discussion, theoretical analysis, and rigorous empirical treatment of the interplay between tax policy and tax evasion.