Tax Law

The focus of this book is on the interaction of the international tax law regime with other legal regimes, such as the international trade law or the investment law regime.

This unique tool provides an understanding of the underlying policy governing international tax rules as well as how foreign tax laws interact with Canadian laws.

This text discusses the fundamental notions of international taxation, the matter of foreign affiliates, with new chapters on reallocation of taxing rights and global minimum tax and collection of foreign tax debts.

Tax practitioners, multinational companies and national tax authorities have relied on this indispensable resource since its first edition over two decades ago. The Primer provides the reader with an introductory analysis of the major issues that a country must confront in designing its international tax rules and coordinating those rules with the tax systems of its trading partners, with numerous examples drawn from the practices of both developed and developing countries. This fifth edition follows the format and sequence of earlier editions, with updates on ongoing developments with respect to the Organisation for Economic Co-operation and Development''s (OECD) base erosion and profit shifting project, the revisions to the OECD Guidelines on Transfer Pricing, and updates to the OECD and UN Model Conventions. Several new sections have been added to the fifth edition.

This title is a new casebook that would primarily be used in academic circles on International Income Tax Law. This book will provide coverage of this subject, including income from Employment, Income from Businesses, Gains and losses from Taxable Canadian Property, Taxation of Canadian residents on foreign income, and much more. This title offers complementary content to the Canadian Income Tax Law casebook (co-authored by David Duff), which does not cover international aspects of income taxes.