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Full-Text Articles in Taxation-Transnational
Deeper Into The Knight: Exploring Deans Knight And Its Effects On The Canadian Gaar, Jinyan Li, Marshall Rothstein, Steve Suarez, Jeffrey Trossman
Deeper Into The Knight: Exploring Deans Knight And Its Effects On The Canadian Gaar, Jinyan Li, Marshall Rothstein, Steve Suarez, Jeffrey Trossman
Articles & Book Chapters
This article discusses the most recent decision of the Supreme Court of Canada in Deans Knight Income Corporation v. Canada (2023) and explores its implications for the Canadian GAAR.
The Pillar 2 Undertaxed Payments Rule Departs From International Consensus And Tax Treaties, Jinyan Li
The Pillar 2 Undertaxed Payments Rule Departs From International Consensus And Tax Treaties, Jinyan Li
Articles & Book Chapters
The OECD released pillar 2 model rules last December to provide a template for domestic legislation to implement the agreement reached on October 8, 2021, by almost 140 inclusive framework members on a two-pillar solution to address global ta challenges. The model rules are limited to the income inclusion rule (IIR) and undertaxed payments rule (UTPR) (collectively known as the global anti-base-erosion (GLOBE) regime) in the October agreement. However, and rather surprisingly, the meaning of the letter “P” in the UTPR was effectively changed from payments to profits in the model rules. There was little, if any, public discussion about …
Finding The Purpose Of Tax Treatyprovisions Under Gaar: Lessons From Alta Energy, Jinyan Li
Finding The Purpose Of Tax Treatyprovisions Under Gaar: Lessons From Alta Energy, Jinyan Li
Articles & Book Chapters
Establishing the object and purpose of tax treaty provisions lies at the heart of applying antiabuse rules, such as general antiavoidance rules under domestic law and the principal purpose test (PPT) in tax treaties. Tax planning arrangements like treaty shopping, designed to obtain treaty benefits, are not abusive unless they contravene the object and purpose of the provisions relied upon by the taxpayer.