Tax avoidance, a concept increasingly familiar to most developed countries, has assumed dominant presence in international taxation. The subject was the focus of the International…
It is a fundamental principle of Anglo-Canadian law that a taxpayer is entitled to arrange his or her affairs to minimize tax. The frequently decision…
The law says that a taxpayer is entitled to legally arrange her affairs to mitigate tax. Tax planning involves analysis of legislation and its judicial…
Agreements for the avoidance of double taxation are bilateral Conventions (herein, sometimes referred to as “treaties”) between sovereign States. The personal scope article of the…
A country’s revenue laws reflect its political sovereignty and create property rights that affect relationships. Hence, sovereign states will not enforce the revenue laws of…
2022 was not a good year for investors. Stocks and bonds tumbled, and bitcoin crumbled. The S&P/TSX composite index was down 8.7%; the S&P 500…
The Department of Finance’s consultation paper in which it outlines various proposals to bolster the General Anti-avoidance Rule (“GAAR”) in section 245 against taxpayers is…
A Bill of Rights typically entrenches rights in the law so that individuals can enforce their rights through the legal process. However, unlike Americans –…
Millions of employees forced to work from home because of COVID-19 turned their bedrooms, basements, and kitchens into workspaces. In doing so, they took on…
Tax rules protect the Tax Collector. They are not intended to protect taxpayers. Taxpayers who do not comply with the rules lose all their rights….
There are very few rules in tax law that protect taxpayers. Most are written to protect the Canada Revenue Agency and the government. The doctrine…
As we go into tax filing season, individuals should consider which employment perquisites of office are taxable and which are not. Employees are compensated through salary…