Tax Avoidance in Canada After Canada Trustco and Mathew
Tax Avoidance in Canada After Canada Trustco and Mathew

Author: David Duff

Publisher:

Published: 2007

Total Pages: 264

ISBN-13: 9781552211335

DOWNLOAD EBOOK

These nine articles analyze the decisions made by the Supreme Court and Tax Court of Canada, specifically addressing the General Anti-Avoidance Rule (GAAR) in section 245 of the Canadian Income Tax Act. More generally, the book reflects on the role of a GAAR by considering other cases in Canada and abroad, as well as the design and implementation of an effective GAAR.

Taxation of Intercompany Dividends Under Tax Treaties and EU Law
Taxation of Intercompany Dividends Under Tax Treaties and EU Law

Author: Guglielmo Maisto

Publisher: IBFD

Published: 2012

Total Pages: 1093

ISBN-13: 9087221398

DOWNLOAD EBOOK

This book is a detailed and comprehensive study on the taxation of cross-border dividend distributions. It first considers cross-border dividend taxation in the context of EU law. In this field, issues such as the jurisprudence of the European Court of Justice, the hindrance to the internal market caused by double taxation of dividends and the compatibility of dividend withholding taxes are dealt with. Next, the book discusses the taxation of dividends under tax treaties, in particular focusing on the definition of "dividends" in the OECD Model Convention and the meaning of the concept of "beneficial owner" as applied to dividends. The application of domestic and agreement-based anti-abuse rules to dividends is thoroughly analysed. Finally, the relevance of the non-discrimination provision enshrined in Art. 24 of the OECD Model Convention to dividends as well as procedural issues relating to treaty relief and possible ways of improvement are taken into consideration. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and non-European jurisdictions.

Legislating Against Tax Avoidance
Legislating Against Tax Avoidance

Author: Rachel Anne Tooma

Publisher: IBFD

Published: 2008

Total Pages: 405

ISBN-13: 9087220340

DOWNLOAD EBOOK

Proposes a uniform statutory GAAR for the Federation of Australia, and examines "the experiences of countries with (e.g., Australia, Canada, New Zealand and South Africa) and without (e.g., the United States of America and the United Kingdom) a statutory GAAR"--Page ix.

International Taxation of Permanent Establishments
International Taxation of Permanent Establishments

Author: Michael Kobetsky

Publisher: Cambridge University Press

Published: 2011-09-15

Total Pages: 469

ISBN-13: 1139500228

DOWNLOAD EBOOK

The effects of the growth of multinational enterprises and globalization in the past fifty years have been profound, and many multinational enterprises, such as international banks, now operate around the world through branches known as permanent establishments. The business profits article (Article 7) of the OECD model tax treaty attributes a multinational enterprise's business profits to a permanent establishment in a host country for tax purposes. Michael Kobetsky analyses the principles for allocating the profits of multinational enterprises to permanent establishments under this article, explains the shortcomings of the current arm's length principle for attributing business profits to permanent establishments and considers the alternative method of formulary apportionment for allocating business profits.

Canadian Income Taxation
Canadian Income Taxation

Author: W. J. Buckwold

Publisher: McGraw-Hill Ryerson

Published: 2007

Total Pages: 740

ISBN-13: 9780070978881

DOWNLOAD EBOOK

Heavily updated for the 2006-2007 Edition, Canadian Income Taxation: Planning and Decision Making reflects recent changes in the 2005 and 2006 federal budgets, as well as new coverage of trusts, expanded problem and review material, and in-depth coverage of the widespread changing relationships that result from the new dividend tax credit regime. Developed with students in mind, Canadian Income Taxation: Planning and Decision Making is centred on analysis, not just memorization, an approach designed to help you make the right decision at the right time. Combining in-depth analysis with a renowned student-friendly approach, this text is your bridge to knowledge, skill, and success.

101 Tax Secrets For Canadians
101 Tax Secrets For Canadians

Author: Tim Cestnick

Publisher: John Wiley and Sons

Published: 2010-07-15

Total Pages: 368

ISBN-13: 047067881X

DOWNLOAD EBOOK

Nothing can better protect hard-earned income and help to accumulate wealth than savvy tax strategies. In this comprehensive guide, Canada's foremost tax expert, Tim Cestnick, offers 101 tips for year-round tax planning that can save Canadians from all walks of life thousands of dollars on their tax bill. It shows readers how they can best build a successful game plan that will reduce their taxes and maximize after-tax investment returns. Cestnick's simple and proven advice makes 101 Tax Secrets for Canadians an essential tool for all Canadians seeking to accumulate wealth and protect their income.

Income Tax Law
Income Tax Law

Author: Vern Krishna

Publisher:

Published: 2012

Total Pages: 746

ISBN-13: 9781552212356

DOWNLOAD EBOOK

This book is a comprehensive, up-to-date treatise on income tax law in Canada. The book introduces students and practitioners to income tax law in its broadest dimensions. It addresses the subject matter based on principles, policy, and practice. The objective is to explain what the law is, why it is the way it is, and how it works (or does not).

GAARs and Judicial Anti-Avoidance in Germany, the UK and the EU
GAARs and Judicial Anti-Avoidance in Germany, the UK and the EU

Author: Markus Seiler

Publisher: Linde Verlag GmbH

Published: 2016-06-28

Total Pages: 336

ISBN-13: 3709408164

DOWNLOAD EBOOK

GAARS: the better insight into a country’s tax system In a post-BEPS tax world and in times of an ever-increasing need for tax revenue, policy-makers are more willing than ever to tighten or adopt General Anti-Avoidance Rules (GAARs). A GAAR is typically a broad principle-based rule trying to establish the borderline between “abuse” and “use” of a law, thereby addressing the phenomenon that as long as there have been taxes, persons have been trying to reduce their tax bills. This award-winning book compares the GAARs and judicial anti-avoidance approaches of Germany, the UK and the EU. It gives a deep insight into the predominant legal traditions of the Western World, comprehensively analyses case-law and offers unique perspectives on tax law across jurisdictions. This book reveals that there is no other feature of tax law that provides a better insight into a country’s tax system than its anti-avoidance rules. GAARs and their historical background reveal so much about judicial perspectives on taxation and legal interpretation, citizens’ tax morale, drafters’ inclinations for technical or principled drafting or legislators’ willingness to confront politically sensitive issues. Understanding the role of GAARs ultimately also reveals whether they are a suitable means to counteract tax avoidance effectively. The Book is the winner of the Wolfgang Gassner-Wissenschaftspreis 2016!