business property, listed shares, and minority "non-substantial" interests no longer manifest Canada's current tax treaty …

Kingdom, Canada and the United States; as well as its varied and increasing uses in international tax law. By analysing the …

Recently, in CIBC World Markets Inc. v. R. (“CIBC case”), the Chief Justice of the Tax Court of Canada (“TCC”) was … faced with an issue that was novel to Canada's consumption tax jurisprudence. Can a GST registrant retrospectively change …'s attempt at legal cross-fertilization (or tax transplantation) on the basis that Canada's GST system is “somewhat different …

Canada's relatively low profile in the global market for offshore financial services. Overall, Canada's tax regime attempts … countries to enforce their tax laws in respect of their residents who invest in Canada …