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The Future Of The Corporate Form In Income Tax: A Case Study Of Canada, Jinyan Li
The Future Of The Corporate Form In Income Tax: A Case Study Of Canada, Jinyan Li
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A corporation is nothing but a piece of paper. And yet, this piece of paper enjoys the status of a person and has an independent identity as a taxpayer (the “separate entity principle”). It can generate tremendous value for its shareholders through tax savings resulted from tax deferral, tax shifting, and tax subsidies. Why does tax law allow such value to exist? Is there any hard line constraining the scope of the tax benefits associated with the corporate form? To what extent can the two pillars (Pillar One and Pillar Two) crush the corporate form? What is the future of …
The Global Tax Agreement: Some Truths And Legal Realities, Jinyan Li
The Global Tax Agreement: Some Truths And Legal Realities, Jinyan Li
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With much pomp and ceremony, it was announced that member jurisdictions of the G20/OECD BEPS Inclusive Framework “agreed to a two-pillar solution to address the tax challenges from the digitalization of the economy” (the “Two-Pillar Agreement”) This agreement has been hailed by some as “historic”, “momentous”, “revolutionary”, but criticized by others as “harmful to developing countries”, cartelistic power grabbing by a few powerful countries, or neocolonialism. So, is the agreement a cause for celebration or the opposite? What is the chance of the Agreement become real law? In this article, I try to first explain what the two-pillar agreement is …
Tax Reform: A Missing Piece In Canada's National Housing Policy, Jinyan Li
Tax Reform: A Missing Piece In Canada's National Housing Policy, Jinyan Li
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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
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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 …