2020
|
| 193 |
December 23 |
Farewell To 2020, A Thank You To Brian Ernewein, And Season’s Greetings
|
| 192 |
December 11 |
The Fall Economic Statement
|
| 191 |
December 2 |
Proposed Article 12b of the United Nations Model Convention
|
| 190 |
November 17 |
The Australian Taxation Office’s Views Of The Purpose Tests In The Australian General Anti-Avoidance Rule And The Principal Purpose Test
|
| 189 |
November 2 |
Interest Deductibility
|
| 188 |
October 20 |
Another Fascinating GAAR Decision: Gladwin Realty
|
| 187 |
October 8 |
An Update on Pillar Two
|
| 186 |
September 29 |
What Is The Statutory Scheme For Loss Trading?
|
| 185 |
September 17 |
An Increase In A Tax Attribute Is Not A Tax Benefit
|
| 184 |
August 25 |
Is A Canadian Bank Subject To UK Tax On UK Resource Profits?
|
| 183 |
August 11 |
Supreme Court Grants Leave To Appeal In Alta Energy Luxembourg
|
| 182 |
July 14 |
Diving, Deeming, and Tax Treaties
|
| 181 |
June 29 |
LawPro Loses Its Appeal (revised)
|
| 180 |
June 8 |
The Federal Court of Appeal Affirms The Tax Court Decision In The Bank of Montreal Case
|
| 179 |
May 27 |
Why Does A Canadian Grocery Store Chain Need a Tax Haven Bank?
|
| 178 |
May 20 |
Some Thoughts on Tax Certainty
|
| 177 |
May 5 |
Tax Reform in a Post-Covid-19 World
|
| 176 |
April 28 |
Nicolas Cage, Audi, Dubai, India, and Withholding Tax |
| 175 |
April 14 |
The Federal Government's Measures in Response to the Covid-19 Pandemic |
| 174 |
April 8 |
The Coronavirus Pandemic |
| 173 |
March 23 |
Supreme Court Affirms Federal Court of Appeal Decision in MacDonald: Gains and Losses from Hedging of a Capital Asset are on Capital Account |
| 172 |
March 17 |
US International Tax Issues: A View from the Congressional Research Service |
| 171 |
March 2 |
Treaty Shopping: Thriving in Canada |
| 170 |
February 13 |
Conduct Unbecoming by the Law Society of Ontario |
| 169 |
January 29 |
A Shameful Sham |
| 168 |
January 16 |
The Prime Minister's Mandate Letter to the Minister of Finance |
2019
|
| 167 |
December 19 |
A Weird Decision on Tax Treaties |
| 166 |
November 28 |
The Changing Face of International Taxation: The OECD's Pillar One and Pillar Two Proposals |
| 165 |
November 14 |
Down Under Yet Again |
| 164 |
November 6 |
The People Have Spoken: What's Next for the Canadian Tax System? |
| 163 |
October 16 |
The Parties’ Election Promises: A Pox on All Your Promises |
| 162 |
October 10 |
Estate Freezes: A Hot-Button Issue |
| 161 |
August 30 |
Full or Partial Foreign Tax Credit? |
| 160 |
August 7 |
The Government Wins Another GAAR Case: Birchcliff Energy |
| 159 |
July 15 |
A Critical Analysis of the International Monetary Fund's Sample General Anti-Avoidance Rule (GAAR) |
| 158 |
July 3 |
50 Years and Counting |
| 157 |
June 18 |
The Future of International Tax II: “Nobody told me there’d be days like this . . . strange days indeed” – The Beatles |
| 156 |
June 6 |
The Future of International Tax I: The Most Recent OECD Proposals About the Digital Economy |
| 155 |
May 13 |
Britacom And The First Belt and Road Initiative Tax Administration Cooperation Forum Conference, Wuzhen, China |
| 154 |
May 3 |
Tax Certainty |
| 153 |
April 23 |
International Monetary Fund Study on Corporate Taxation in the Global Economy |
| 152 |
March 20 |
Canada Adopts The Multilateral Legal Instrument |
| 151 |
March 11 |
Canadian Thin Capitalization Rules and Tax Treaties |
| 150 |
February 19 |
Tax Reform Proposals for the 2019 Budget |
| 149 |
January 29 |
Robert J. Sharpe, Good Judgment: Making Judicial Decisions (Toronto: University of Toronto Press, 2018) |
| 148 |
January 18 |
30 Years of GAAR: It's a rap |
2018
|
| 147 |
December 19 |
The Fall Economic Statement and Season's Greetings |
| 146 |
December 17 |
30 Years of the GAAR |
| 145 |
November 26 |
Another Interesting GAAR Case |
| 144 |
November 14 |
Restrictions on the Deduction of Interest |
| 143 |
October 31 |
A Tangled Web |
| 142 |
October 25 |
The Application of the GAAR to an Ancillary Aspect of a Tower Structure: Bank of Montreal V. The Queen |
| 141 |
October 9 |
Treaty Shopping: The Spawn of Mil (Investments) |
| 140 |
September 17 |
Does a Tax Benefit Have to Be Realized? Wild v. Canada 2018 FCA 114 |
| 139 |
August 29 |
The Most Frightening and Most Optimistic Books I've Ever Read |
| 138 |
July 31 |
Cash Settlement of a Derivative Contract - Capital or Income? |
| 137 |
July 16 |
United States Supreme Court Adopts New Substantial Nexus Threshold for Interstate Commerce |
| 136 |
June 27 |
Greetings from Mongolia! |
| 135 |
June 19 |
A Case Study in Interpretation: The GST New Housing Rebate II |
| 134 |
June 9 |
A Case Study in Interpretation: The GST New Housing Rebate I |
| 133 |
May 30 |
Report of the Independent Commission for the Reform of International Corporate Taxation (ICRICT) |
| 132 |
May 18 |
Recent Developments with Respect to the Taxation of Digital Activities |
| 131 |
May 2 |
Reflections on the Determination of Abuse Under the General Anti-Avoidance Rule |
| 130 |
April 10 |
Provincial Taxation and the Digital Economy |
| 129 |
April 2 |
US Tax Reform IV: International Aspects |
| 128 |
March 27 |
US Tax Reform III: International Aspects |
| 127 |
March 9 |
US Tax Reform II – Business and Corporate Aspects |
| 126 |
February 27 |
The Federal Court of Appeal Decisions in Univar and Oxford Properties |
| 125 |
February 14 |
US Tax Reform I – Background and Personal Tax Aspects |
124
|
January 26
|
CRA's Policy on Employee Discounts
|
2017
|
123
|
December 21
|
Season’s Greetings
|
| 122 |
November 29 |
The Sorry Saga of the Private Corporation Proposals |
| 121 |
November 22 |
Taxation of Gains from Indirect Transfers |
| 120 |
October 6 |
Tom McDonnell’s Review of Breakdown – The Inside Story of the Rise and Fall of Heenan Blaikie |
119
|
September 13
|
Finance Consultation Paper on the Taxation of Private Corporations IV: Proposals to Deal with Passive Income |
118
|
September 13
|
Finance Consultation Paper on the Taxation of Private Corporations III: Proposals to Deal with Income Sprinkling |
117
|
September 11
|
Finance Consultation Paper on the Taxation of Private Corporations II: Proposals to Deal with Surplus Stripping |
116
|
August 30
|
Finance Consultation Paper on the Taxation of Private Corporations I: General Comments
|
115
|
August 8
|
A High Level Conference on International Taxation in Asean Countries
|
114
|
July 19
|
The Multilateral Instrument: Canada’s Position II – Mutual Agreement Procedure and Mandatory Arbitration |
113
|
July 6
|
The Multilateral Instrument: Canada’s Position I – General and Treaty Abuse |
112
|
June 20
|
The CBC Does it Again |
111
|
May 19
|
A Brief Follow-Up Interview with Donald Trump and a Primer on US Tax Reform |
110
|
April 28
|
Several Unrelated Issues
|
109
|
March 13
|
Is Tax Avoidance Legal? |
108
|
February 27
|
Report of the Finance Committee and Results of the Survey Concerning Tax Reform |
107
|
January 20
|
Tax Court GAAR Decisions in Oxford Properties and Univar |
2016
|
106
|
December 22
|
Does Canada Need a Comprehensive Study on Tax Reform? |
105
|
December 12
|
The Multilateral Instrument |
104
|
November 25
|
12th Session of the United Nations Committee of Experts |
103
|
October 28
|
Two Recent Tax Treaty Cases |
102
|
October 11
|
An Interview with Donald J. Trump
|
101
|
September 19
|
Federal Court of Appeal Overturns Tax Court Decision in Kruger |
100
|
August 8
|
Special Report: A Tribute to Larry Chapman |
099
|
July 25
|
Another Provincial GAAR Case: Veracity Capital
|
098
|
June 22
|
Report of the Proceedings of a Conference on the 100th Anniversary of the Canadian Income Tax Act |
| 097 |
May 16
|
Miscellany: The Panama Papers, The CBC, and Treaty Shopping |
096
|
April 25
|
Down Under Again
|
095
|
April 8
|
Still Crazy After All These Years: The TDL Group Co. v. The Queen |
| 094 |
March 23
|
Global Tax Policy Conference: An Update on BEPS |
093
|
March 3
|
Atlantic Icon – Ed Harris |
092
|
February 10
|
“Till Death Do Us Part” . . . or Maybe Even Thereafter |
| 091 |
January 14
|
BEPS: Paradigm Shift? The Most Fundamental International Tax Change in a Century? |
2015
|
090
|
December 14
|
Should Tax Reform Be on the New Government’s Agenda?
|
| 089 |
November 6
|
The Final BEPS Reports |
088
|
October 23
|
KPMG Offshore Tax Planning Caught in the Headlines and the Headlights
|
087
|
October 2
|
The Federal Court Rejects Challenge to FATCA
|
086
|
August 28
|
The Supreme Court Rejects the Taxpayer’s Appeal in Guindon |
| 085 |
August 14 |
A Tribute to the Canadian Tax Foundation |
| 084 |
July 16 |
The Tax Treatment of Foreign Currency Options; the Kruger Case |
083
|
July 6
|
Interest Deductibility Again: TDL Group Co. v. The Queen |
082
|
June 10
|
The OECD BEPS Discussion Draft on Controlled Foreign Corporation (CFC) Rules |
| 081 |
May 21 |
Writing Well |
| 080 |
April 29 |
Tom McDonnell |
| 079 |
April 1 |
Canada Revenue Agency to Change Name to Canada Funding Services Agency |
078
|
March 23
|
Report from Australia
|
077
|
March 5
|
Interest Deductibility II: What Should Canada Do? |
076
|
February 19
|
Interest deductibility I: OECD BEPS Action 4 |
075
|
February 5 |
The Grand Old Man of Canadian Tax |
074
|
January 21
|
What Do You Get When You Mix the Repayment of Debt, Foreign Currency and a Corporation’s Own Shares? |
2014
|
| 073 |
December 19
|
The Inter-Leasing Case: Formalism, The Easy Way |
| 072 |
December 3 |
BEPS and Developing the Countries |
| 071 |
November 14 |
BEPS and Treaty Abuse – II |
| 070 |
October 20 |
BEPS and Treaty Abuse – I |
| 069 |
October 9 |
The Gervais Case and the Split Personality of Shares |
| 068 |
September 4 |
New Protocol to the Canada-UK Treaty |
| 067 |
August 14 |
The Votes Are In! |
| 066 |
June 26 |
Mamas Don't Let Your Babies Grow Up To Be Tax Advisers
|
| 065 |
May 30 |
The Lehigh Decision – Correct but not convincing? |
| 064 |
April 16 |
OECD BEPS Treaty Abuse Proposals |
| 063 |
March 31 |
Evolution and Tax Systems |
| 062 |
March 18 |
Treaty Shopping Revisited |
| 061 |
February 24 |
“Singing words of wisdom, let it be …” The Beatles, 1970 |
| 060 |
February 6 |
Tax Preparers Prepare to be Re-educated! |
| 059 |
January 14 |
Setting the Bar for Tax Advisers |
2013
|
| 058 |
November 12 |
Issue 058 |
| 057 |
October 23 |
Shopping for Tax Treaties |
| 056 |
September 10 |
Should Tax Advice Provided by Accountants Have Privilege? |
| 055 |
August 28 |
Robert McMechan, Economic Substance and Tax Avoidance... |
| 054 |
July 30 |
The Tax Policy-Making Process |
| 053 |
July 15 |
Professor John Tiley - In Memoriam |
| 052 |
July 2 |
Issue 052 |
| 051 |
June 3 |
Professor Neil Brooks retires, and a couple of other things |
| 050 |
May 6 |
Speech by the Honourable Donald G. H. Bowman, Q.C. |
| 049 |
April 26 |
Morality, Taxation, and Morning Coffee |
| 048 |
April 10 |
Lipson Redux |
| 047 |
April 1 |
Issue 047 |
| 046 |
March 12 |
Interest Deductibility |
| 045 |
February 25 |
30th Anniversary of the Tax Court of Canada |
| 044 |
February 14 |
The GAAR Trilogy |
| 043 |
February 7 |
David A. Ward – A Tribute
|
| 042 |
January 8 |
Scalia’s Folly: Scalia and Garner on Statutory Interpretation
|
2012
|
| 041 |
December 20 |
Musings on the Supreme Court’s View of the Concept of Abuse under the GAAR |
| 040 |
November 19 |
The Supreme Court, Transfer Pricing, and Drugs |
| 039 |
November 6 |
The Revised and Much-Improved Draft UK General Anti-Avoidance Rule |
| 038 |
October 11 |
Professor Hugh Ault and the Boston IFA Congress |
| 037 |
September 11 |
The Sommerer Case |
| 036 |
September 5 |
Summertime |
| 035 |
August 15 |
Moving On … With a little help from the Tax Court |
| 034 |
July 12 |
Canada Day |
| 033 |
June 18 |
Beneficial Ownership under Tax Treaties |
| 032 |
June 5 |
The Supreme Court’s Decision in Garron |
| 031 |
April 23 |
Better Late than Never |
| 030 |
April 5 |
Aussie and Yankee Recent Developments |
| 029 |
March 9 |
The Assumption of Contingent Liabilities as Proceeds of Disposition: The Daishowa Case |
| 028 |
March 1 |
Professor Doctor Albert Raedler |
| 027 |
February 15 |
Silly Season |
| 026 |
January 16 |
The Proposed UK General Anti-Avoidance Rule |
2011
|
| 025 |
December 22 |
The Canadian Tax System Gets a Christmas Present from the Supreme Court |
| 024 |
December 16 |
The Tax Court’s Trilogy of GAAR Cases |
| 023 |
November 23 |
Government Announces Commitment to Clearer Tax Legislation |
| 022 |
November 10 |
The UN Committee of Experts and the Update of the UN Model Convention |
| 021 |
October 6 |
Waiting for Copthorne – II |
| 020 |
September 29 |
Waiting for Copthorne - I |
| 019 |
September 21 |
Why the General Anti-Avoidance Rule Needs A Penalty |
| 018 |
August 18 |
Tax Simplification – Blah, blah, blah |
| 017 |
August 3 |
A Tax Tourist in South Africa |
| 016 |
July 11 |
Information Influenza |
| 015 |
June 17 |
To consolidate or not to consolidate; to legislate or not to legislate; and how to deal with those pesky provinces – these are just some of the questions |
| 014 |
May 12 |
Just when I thought … Interest Deductibility and the Collins case |
| 013 |
April 20 |
Promises, Promises ... Tax Aspects of the Parties' 2011 Election Platforms |
| 012 |
April 15 |
The Tax Policy Process Again |
| 011 |
March 23 |
Proposed Changes to the Australian CFC and FIF Rules |
| 010 |
March 8 |
From the Land Down Under |
| 009 |
March 1 |
Making Tax Policy and Consultation |
| 008 |
January 31 |
SPAARS and GAAR |
| 007 |
January 17 |
The Land of the Free, the Home of the Brave, and the Economic Substance Doctrine |
| 006 |
January 11 |
Artist or Artiste? – What a difference a letter makes! |
2010
|
| 005 |
December 16 |
The Trouble with Billionaires |
| 004 |
November 25 |
FCA decides in favour of the government in Garron |
| 003 |
November 19 |
Of Scams and Shams - II |
| 002 |
November 9 |
Of Scams and Shams - I |
| 001 |
October 14 |
FIE Fiasco |
| |
October 14 |
Introduction |