Introduction

Note: The views expressed in the Arnold Report are those of Brian J. Arnold and are not endorsed by the Canadian Tax Foundation and should not be attributed to the Canadian Tax Foundation.

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2019
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