This is a chapter of the book that provides a rich context for discussing the Chinese international tax system. It emphasizes the importance of cultural and institutional differences between China and Western democratic countries in understanding the Chinese international tax system

This paper examines one of the most important, and often poorly analyzed, concepts – source of income. It traces the evolution of this concept in Canada and offers insights on the implications of the G20/OECD BEPS project (which, in effect, created some “negative” source rules for business...

This paper pays homage to the Canadian Income War Tax Act, 1917. It is the overview chapter of a monograph titled Income Tax at 100th Years: Essays and Reflections on the Income War Tax Act. It explains why the “birthday” of a statute is worth celebrating: it is a living memoir of nationhood;...

This paper was submitted to the Department of Finance, Canada during the public consultation regarding proposals to eliminate some tax planning advantages for private corporations. It supports the direction of introducing more fairness in the tax system by preventing income-shifting (such as...

This article is based on a submission to the Advisory Panel of Canada's System of International Taxation. It discusses the general approach to tax reform and the specific questions about redesigning the outbound tax system. The main thesis is that the neutrality theories (CIN, CEN and CON) are...

This is the report of a mission of the IMF Legal Department which visited the People's Republic of China in May 1993. The purpose of this mission was to explore the questions: "What does the rule of law mean for the tax system of China? What changes would have to be made to the system to better...

This paper seeks to explore the above question by drawing insights from existing literature. The existing body of literature is rich in documenting the phenomenon of legal transplants, theorising why legal transplants take place and presenting the debate on the relevance of local culture to the...

The authors report the results of an empirical study on the general anti-avoidance rules (GAARs) in action in Australia, Canada, and New Zealand. The study builds on a conceptual framework, developed by Tim Edgar, that classifies tax-avoidance transactions as falling into three types...