Full bibliography | SCC-Authors-Cited

Organisation for Economic Co-operation and Development Committee on Fiscal Affairs. (2003). Model tax convention on income and on capital: condensed version, 28 January 2003. OECD.

This publication is the condensed version of the OECD Model Tax Convention on Income and on Capital, which is produced in a loose-leaf format to accommodate yearly updates. This fifth edition contains the full text of the Model Tax Convention as it read on 28 January 2003, but without the historical notes, the detailed list of tax conventions between OECD member countries and the background reports that are included in the loose-leaf version.

Sasseville, J. (1988). Implementation of the General Anti-Avoidance Rule. In Income tax enforcement, compliance, and administration. Canadian Tax Foundation.

Simontacchi, S. (2006). Immovable Property Companies as Defined in Article 13 (4) of the OECD Model. Bulletin for International Taxation, 60(1), 29.

Simontacchi, S. (2007). Taxation of capital gains under the OECD Model Convention: with special regard to immovable property. Kluwer Law International.

Vogel, K. (1986). Double Tax Treaties and Their Interpretation. International Tax & Business Lawyer, 4(1), 1–85. https://heinonline.org/HOL/P?h=hein.journals/berkjintlw4&i=7

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Ward, D. A. (1977). Principles to Be Applied in Interpreting Tax Treaties. Canadian Tax Journal, 25(3), 263–270. https://heinonline.org/HOL/P?h=hein.journals/cdntj25&i=272

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Ward, D. A. (2005). The interpretation of income tax treaties with particular reference to the commentaries on the OECD model. International Fiscal Association Canadian Branch.

Li, J. (with Cockfield, A. J., & Wilkie, J. S.). (2018). International taxation in Canada: principles and practices (Fourth edition.). LexisNexis.

The first comprehensive book on Canadian international tax law, International Taxation in Canada {u2013} Principles and Practices was originally published in 2006. Now in its fourth edition, it has become the leading book on this topic in Canada and is the most widely-adopted book for classroom usage at Canadian law schools. A unique and resourceful tool, it provides an understanding of the underlying policy governing international tax rules as well as how foreign tax laws interact with Canadian laws.

Li, J. (with Cockfield, A. J., & Wilkie, J. S.). (2011). International taxation in Canada: principles and practices (2nd ed.). LexisNexis.

Davies, D. R. (1985). Principles of international double taxation relief. Sweet & Maxwell.

Avi-Yonah, R. S. (with Sartori, N., & Marian, O.). (2011). Global perspectives on income taxation law. Oxford University Press.

Arnold, B. J., & Wilson, J. R. (2014). Aggressive International Tax Planning by Multinational Corporations: The Canadian Context and Possible Responses. Research Paper No. 29, 2014., 7. https://doi.org/10.55016/ojs/sppp.v7i1.42484

Aggressive international tax planning by multinational corporations has lately fallen under intense political scrutiny. U.S. politicians have called out some American multinationals, including Apple, Amazon, Starbucks and Google, for relocating profits abroad to avoid American taxes. More recently, politicians accused Burger King of being unpatriotic for its own purported “tax inversion” maneuver, in which it would acquire Canada’s Tim Hortons and shift the head office from Florida to Ontario, benefitting from the lower northern tax rates. The Chicago-based Walgreens pharmacy chain recently backed off a “tax inversion” plan to relocate to Switzerland (the former headquarters of Alliance Boots, a company acquired by Walgreens), apparently having assessed the political risk as too high. This sort of aggressive international tax planning by multinational corporations was what G20 members had committed to fighting against when they endorsed the OECD’s “action plan” against base erosion and profit shifting (BEPS). Canada has been vigilant about improving its tax framework to prevent non-resident corporations from eroding the Canadian tax base, having enacted thin-capitalization rules and, more recently, foreign-affiliate-dumping rules, as well as proposing anti-treaty-shopping measures. But despite Canada’s commitment to the OECD’s BEPS Action Plan, the Canadian government has been reluctant to follow through on implementing rules that might affect its own resident corporations and their international competitiveness. This is most notably visible in the generous participation exemption for dividends from foreign affiliates, the absence of rules restricting the deductibility of interest expenses incurred to earn exempt dividends from foreign affiliates. Canada may be reluctant to fully follow through on all aspects of the OECD’s BEPS Action Plan. As the examples of Apple, Amazon, Google and Starbucks demonstrate, the American government has so far been unable to bring itself to take any meaningful action against aggressive international planning by U.S.resident corporations. Were Canada to enact and enforce rules that clamped down on aggressive international tax planning by its own resident corporations, it would only put Canadian firms at a competitive disadvantage relative to American (or other international) rivals. Until the United States is willing and able to take the lead on aggressive international tax planning by multi-national corporations, the reality is that smaller countries, including Canada, should be cautious about making changes to its international tax rules that are dependent on other countries making similar changes.

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Arnold, B. J. (2004). Tax treaties and tax avoidance: the 2003 revisions to the Commentary to the OECD Model. Bulletin for International Fiscal Documentation, 58(6), 244–260.

Arnold, B. J. (with Canadian Tax Foundation). (2009). Reforming Canada’s international tax system: toward coherence and simplicity. Canadian Tax Foundation.

Arnold, B. J. (2001). Reflections on the Relationship between Statutory Interpretation and Tax Avoidance. Canadian Tax Journal, 49(1), 1–39. https://heinonline.org/HOL/P?h=hein.journals/cdntj49&i=17

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Anonymous. (2021, May 15). The big carve-up. The Economist, 439(9245), 69–70. https://www.proquest.com/docview/2527502376/abstract/64EE7CA2869448D6PQ/62

[...]taxing rights are allocated first to wherever profits are produced (the "source") and then to wherever the parent company is headquartered (or "resident"). [...]tax competition has encouraged companies to shuffle their reported profits to low-tax places. [...]any deal will involve compromises.

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Canada v. Alta Energy Luxembourg S.A.R.L. - 2021 SCC 49 (November 26, 2021). https://decisions.scc-csc.ca/scc-csc/scc-csc/en/item/19089/index.do

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Kreke v. Alansari - 2021 SCC 50 (December 2, 2021). https://decisions.scc-csc.ca/scc-csc/scc-csc/en/item/19098/index.do

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Panteleo, N., & Smart, M. (2012). International Considerations. In H. Kerr, K. J. McKenzie, J. M. Mintz, B. J. Arnold, & Canadian Tax Foundation (Eds.), Tax policy in Canada (p. 12:1). Canadian Tax Foundation.

Krishna, V., & Khirdaji, N. (2019). Income tax (International), 2019 reissue (First edition.). LexisNexis Canada.

Canada imposes taxes based on taxpayer residence and on the source of income, and the rules relating to this international taxation are complex. This title presents a straightforward and lucid explanation of those rules, and how they are applied by the taxing authorities.

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