We present here the first machine-generated law review article. Our self-interest motivates us to believe that knowledge workers who write complex articles drawing upon years of research and effort are safe from AI developments. However, how reasonable is it to persist in this belief given...

Tax-free savings accounts (quot;TFSAsquot;) became available in Canada in January 2009. A TFSA is a quot;tax prepaidquot; or quot;yield-exemptquot; investment account that does not provide any deduction for contributions and allows for tax-free compounding of investment returns in addition to...

Internet use has grown dramatically in Canada in recent years. This trend has joined with the increasing popularity and social legitimacy in Canada of gambling to produce an environment that is particularly receptive to the growth of online gambling. Online gambling sites compete with gambling...

Tim Edgar's contributions to our understanding of tax avoidance and anti-avoidance remain ahead of their time. In this paper, the author argues that Edgar's work on building better general anti-avoidance rules (GAARs) was particularly prescient — correct in its claim that tax avoidance can and...

The economic substance doctrine is intended to prevent taxpayers from engaging in transactions that have no substantive purpose other than to obtain a tax benefit. As one of the judicially-created substance-over-form doctrines, its meaning is almost entirely derived from the series of court...

The debt-versus-equity question is largely relegated to the common law. The central inquiry is the “extent to which the transaction complies with arm's length standards and normal business practice.” The courts have established a list of recurring factors to determine whether a transfer...

This article examines a specific category of legal transfers between the United Kingdom and Canada, considering the legacy of UK tax concepts in Canadian income tax law. Two main areas are considered where, in our view, this influence has been most profound: (i) the concept of income deployed...

Over the past 25 years, the justices of the Supreme Court of Canada have not exhibited the divergent policy views along party lines that have been characteristic of the justices of the United States Supreme Court. This apparent lack of partisan polarization in Canada may at first give rise to...