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Full-Text Articles in Law
The Administration Of Canada’S Transfer Pricing Rules: Issues And Recommendations, Jinyan Li, Pierre Barsalou, John Oatway, François Vincent
The Administration Of Canada’S Transfer Pricing Rules: Issues And Recommendations, Jinyan Li, Pierre Barsalou, John Oatway, François Vincent
Commissioned Reports, Studies and Public Policy Documents
No abstract provided.
International Mobility Of Highly Skilled Workers In The Canadian Context: Tax Barriers And Reform Options, Jinyan Li
Commissioned Reports, Studies and Public Policy Documents
No abstract provided.
Improving Inter-Nation Equity Through Territorial Taxation And Tax Sparing, Jinyan Li
Improving Inter-Nation Equity Through Territorial Taxation And Tax Sparing, Jinyan Li
All Papers
The current international tax system allocates the taxation of cross-border income by reference to the residence of the taxpayer and/or the source of income. The governing rules are contained in domestic tax laws and bilateral tax treaties. As noted by Professor Easson, the current regime of allocation is not based on any real agreement between nations and cannot be rationalized by any “obvious principle of fairness”. In fact, it is biased in favour of the capital exporting nations that devised the rules of the game. In order to improve fairness, Professor Easson considered it desirable to have some “redistribution” in …