Among the ways in which multinational enterprises (MNEs) can shift profits from one jurisdiction to another in order to minimize taxes, one of the most simple and widely-employed involves the payment of interest to related parties and third parties. For these reasons, it is not surprising that...

On 4 February 2021, in a panel on “Digitalisation of the Economy: OECD Blueprints Discussion” at the Canadian Tax Foundation’s virtual Transfer Pricing Conference, I spoke about possible winners and losers from the OECD’s Pillar One “Amount A” proposals. My estimates focused on tax...

Canadian National Report prepared for the Vienna University of Economics and Business, Conference on tax secrecy and transparency, Rust, Austria, July, 2012. The aim of the project is to assess how different countries regard the treatment of tax information and tax secrecy. Topics include the...

This article reviews academic and government studies that assess the magnitude of Canadian offshore tax evasion, as well as what tax-haven data leaks such as the Panama Papers have told us. This evidence, along with Canada's historically poor performance in auditing, investigating, and...

This book provides a comprehensive analysis of the Organisation for Economic Cooperation and Development’s (OECD) war on offshore tax evasion. The authors explain the new emerging regulatory regimes on the global exchange of information to combat offshore tax evasion and analyse why Automatic...

GlaxoSmithKline Inc. v. The Queen is a seminal Canadian transfer pricing case. On final appeal to the Supreme Court of Canada, the Minister of National Revenue asked the Court to determine whether the Court of Appeal erred in applying the reasonable business person test. The author critically...