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Full-Text Articles in Law
A Defence Of The Principled Approach To Tax Settlements, Saul Templeton
A Defence Of The Principled Approach To Tax Settlements, Saul Templeton
Dalhousie Law Journal
The Canadian Minister of National Revenue is responsible for administering and enforcing the majority of tax legislation in Canada. Where disputes arise with particular taxpayers over the correct amount of tax owed, the taxpaying public ought to have confidence that the Minister has a principled basis in law for settling disputes for less than amounts previously assessed. Yet opponents of the principled basis for settlement consistently call for reform, arguing that compromise settlement should be permissible. This paper responds to arguments raised for compromise settlement by reconciling the jurisprudence on the authority of the Minister to settle tax disputes. It …
Accountants, Privilege, And The Problem Of Working Papers, Paul Paton
Accountants, Privilege, And The Problem Of Working Papers, Paul Paton
Dalhousie Law Journal
Full and frank disclosure between corporate issuers and their auditors and accounting advisors is critical for maintaining access to the information required for audits and public confidence in the capital markets. While tax authorities in the United States, Australia, New Zealand and the United Kingdom have the power to make broad requests for working papers, in all four jurisdictions, legislation or administrative practice reflects the determination that the best approach for balancing tax and capital markets requirements is for the revenue authorities to seek working papers only in exceptional circumstances. Additionally, limited forms of privilege for accountants have been recognized …
Corporate Nonrecognition Provisions: A Comparison Of The U.S. And Canadian Tax Regimes, Catherine Brown, Christine Manolakas
Corporate Nonrecognition Provisions: A Comparison Of The U.S. And Canadian Tax Regimes, Catherine Brown, Christine Manolakas
Dalhousie Law Journal
This article compares the rules governing the federal income taxation of corporate reorganizations in Canada with those in the United States, including transfers of property to a corporation, corporate divisions, share-for-share exchanges, amalgamations or mergers, recapitalizations, and corporate dissolutions. The paper outlines the provisions governing a particulartype of corporate transaction, compares the Canadian tax results with those of the United States, comments on any differences between particular tax provisions, and examines the practical implications of these differences. The authors conclude that although there are a number of parallels between the U.S. and Canadian tax systems, fundamental differences exist that change …
Taxing Times For Lesbians And Gay Men: Equality At What Cost?, Claire Fl Young
Taxing Times For Lesbians And Gay Men: Equality At What Cost?, Claire Fl Young
Dalhousie Law Journal
In this article I shall briefly review some of those struggles and the current state of the law. This forms the backdrop to an issue that I view as being of fundamental importance to lesbians and gay men in their fight for equality and which has not received much attention; that is the tax system. I shall focus on two aspects. First, I shall analyse the use of the tax system as a spending programme and a tool by which to subsidise particular activities. In this context I shall examine the federal government's refusal to recognise lesbian and gay relationships, …
Behind Closed Doors: How The Rich Won Control Of Canada's Tax System... And Ended Up Richer, Faye Woodman
Behind Closed Doors: How The Rich Won Control Of Canada's Tax System... And Ended Up Richer, Faye Woodman
Dalhousie Law Journal
Linda McQuaig is not an expert. Therein lies an important strength of her book on the Canadian tax system, Behind Closed Doors: How The Rich Won Control of Canada's Tax System ... And Ended Up Richer. Because she is not an expert she has not relied on an insider's knowledge of technical points and jargon and neither has she gotten caught up in a particular disciplines's specialist concerns. Rather, as a good journalist, she has provided a lucid critique of the tax system which will be of interest to anyone concerned with how the tax system is or how it …