Tax Law Commons^™

Panel 3 - Sovereignty In The Age Of Digitalization, Ken Klassen, Yariv Brauner, Ivan Ozai, David Duff

A. Cockfield Memorial Symposium

Chair: Ken Klassen (University of Waterloo)

Yariv Brauner (University of Florida), When Things Break Down: Taxing the Digital Economy in an Even Less Cooperative World

Ivan Ozai (Queen’s University), Taxing Decentralized Governance

David Duff (University of British Columbia), Globalization, Digitalization, and Individual Taxation

Commentators: Lori McMillan (Washburn University); Shay Menuchin (KPMG)

Panel 4 - Ai, Tax Avoidance And Disputes Resolution, Ivan Ozai, Jean-Pierre Vidal, Natalie Goulard, Geoffrey Loomer

A. Cockfield Memorial Symposium

Chair: Ivan Ozai (Queen’s University)

Jean-Pierre Vidal (HEC Motréal) and Natalie Goulard (Spiegel Ryan), Economic Substance in Section 245: Can AI Help Humans?

Geoffrey Loomer (University of Victoria), Tax Treaty Shopping in the Digital Era: Is Canada Responding Effectively?

Commentators: Jeffrey Trossman (Blakes); Catherine Brown (University of Calgary)

Panel 2 - Tax Sovereignty: Legitimate Authority And Boundaries, Geoffrey Loomer, Tsilly Dagan, Jennifer Farrell

A. Cockfield Memorial Symposium

Chair: Geoffrey Loomer (University of Victoria)

Tsilly Dagan (University of Oxford), Rethinking Tax Sovereignty: Between Power and Legitimate Authority

Jennifer Farrell (Western University), Tax implications of the new EU Foreign Subsidies Regulation Rules

Commentators: Stephen Shay (Boston College); Cees Peters (Tilburg University)

Panel 1 - Tax Sovereignty Between Law And Power, Heather Evans, Kim Brooks, Opeyemi Bello, Craig Elliffe, Reuven Avi-Yonah, Blazej Kuzniacki

A. Cockfield Memorial Symposium

Chair: Heather Evans (Canadian Tax Foundation)

Kim Brooks (Dalhousie University) and Opeyemi Bello (University of Manitoba), Amidst Global Hostilities and Retaliatory Tariffs and Taxation: Analyzing How International Tax Policy Can Foster Global Peace

Craig Elliffe (University of Auckland), Taxing Foreigners Discriminatorily: Lessons from the Reserved Anglosphere

Reuven Avi-Yonah (University of Michigan) and Blazej Kuzniacki (Lazarski University), Rule of Law v. Rule of Power: US Tax Defense Measures in Light of the International Law of Countermeasures

Commentators: Shawn Porter (Deloitte); Remi Gagnon (Finance, Canada)

Book Review: Untaxed: The Rich, The Irs,And A New Approach To Tax Compliance, Leslie Book

Faculty Publications

No abstract provided.

Ncti Is The New Gilti, And States Should Still Conform, David Gamage, Darien Shanske

Faculty Publications

This essay continues our series on corporate profit shifting by analyzing how states should respond to the federal One Big Beautiful Bill Act, which transformed GILTI into the new Net Controlled Foreign Corporation Tested Income (NCTI) regime. We argue that states should conform to this new federal provision as a reasonable and legally sound approach to combatting the persistent profit shifting that erodes state tax bases. The 60 percent inclusion rate for NCTI effectively serves as a practical, "rough justice" estimate of income that was economically generated domestically but improperly shifted offshore — an estimate supported by empirical research. We …

The Contemporary Tax Journal Volume 13, No. 2 – Winter 2024

The Contemporary Tax Journal

No abstract provided.

The Contemporary Tax Journal’S Interview With Mr. David Forst, Shuang Zhang

The Contemporary Tax Journal

No abstract provided.

Understanding Section 1202: The Qualified Small Business Stock Exemption, Myra Sutanto Shen

The Contemporary Tax Journal

No abstract provided.

The Second Annual Blockchain Tax Conference On January 24, 2025: Legislative Update – Tax And Non–Tax, Shuang Zhang

The Contemporary Tax Journal

No abstract provided.

The Second Annual Blockchain Tax Conference On January 24, 2025: What’S New With Staking And Mining?, Yamilette Gonzalez

The Contemporary Tax Journal

No abstract provided.

The Second Annual Blockchain Tax Conference On January 24, 2025: What Is Not In The First Final § 6045 Regulations?, Jacob Myers Cpa

The Contemporary Tax Journal

No abstract provided.

The Second Annual Blockchain Tax Conference On January 24, 2025: What Happens When You’Re Paid In Crypto?, Weng Ng

The Contemporary Tax Journal

No abstract provided.

The Deductibility Of Scam Losses: Cca 202511015, Jing Luo

The Contemporary Tax Journal

No abstract provided.

Becker Cpa Review Questions

The Contemporary Tax Journal

No abstract provided.

Sjsu Certificate In Advanced Tax Practice Information

The Contemporary Tax Journal

No abstract provided.

Front Matter (Letter From The Editor, Masthead, Etc.)

The Contemporary Tax Journal

No abstract provided.

The Second Annual Blockchain Tax Conference On January 24, 2025: Overview Of Blockchain Technology And Why It Matters For Tax, Sviatlana Yakavets

The Contemporary Tax Journal

No abstract provided.

The Second Annual Blockchain Tax Conference On January 24, 2025: Putting The Final 6045 Regulations And Form 1099-Da Into Practice, Raymond Clark

The Contemporary Tax Journal

No abstract provided.

The Second Annual Blockchain Tax Conference On January 24, 2025: Ensuring Widespread Implementation Of The Crypto-Asset Reporting Framework (Carf), Jing Luo

The Contemporary Tax Journal

No abstract provided.