The book is a study of the current state of international tax law and its application (or non-application) to electronic commerce in Canada, China, Hong Kong, Japan, Singapore, and the United States. Its purpose is to examine the extent to which current theories and principles of international...

The general anti-avoidance rule (GAAR) in section 245 of the Income Tax Act is about drawing a line between legitimate tax minimization and abusive tax avoidance. However, the GAAR does not provide guidelines for determining whether a particular transaction is legitimate or abusive. In this...

This paper provides an overview of the main features of digital economy and why it poses challenges to existing framework and principles of international taxation. It explains the fiscal impact of these challenges in developing countries. Among the challenges is the “cyberization” of tax...