TAX, SOCIETY & CULTURE

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100 Years of Tax Law in Canada

Published Sep 17, 2017 - Follow author Allison Christians: - Permalink


2017 marks the 100th anniversary of Canada’s federal income tax. In commemoration of this milestone, a half-day symposium will be conducted in conjunction with the Spiegel Sohmer Colloquium on 2 October 2017. The goal of this symposium is to explore the evolution of tax law and policy in Canada over the past century. The symposium will feature a keynote by Kim Brooks followed by two roundtable discussions in which experts confer on some of the key themes of tax law and policy development in Canada. The symposium will conclude with a cocktail reception to celebrate 100 years of federal income tax in Canada.
Symposium Participants:
Kim Brooks, Professor of Law, Dalhousie University. Prof. Brooks is an internationally recognized tax scholar who has written multiple scholarly works on taxation in Canada and beyond.
Jakub Adamski, lecturer in business associations and contract law at McGill Faculty of Law. He runs a seminar on the history and development of corporate law with Marc Barbeau, with whom he is co-authoring a text on the subject.
Marc Barbeau, adjunct professor of corporate and securities law at McGill Faculty of Law and partner, Stikeman Elliott. Me. Barbeau practices in the areas of mergers and acquisitions, complex reorganizations and corporate governance. He runs a seminar on the history and development of corporate law with Jakub Adamski, with whom he is co-authoring a text on the subject.
Scott Wilkie, partner, Blake’s, and Distinguished Professor of Practice at Osgoode Hall Law School, York University. Mr. Wilkie is recognized as a leading corporate tax lawyer in Canada and has extensive experience in national and international corporate tax practice.
Colin Campbell, Associate Professor, University of Western Ontario. Prof. Campbell was a senior partner in the Toronto office of Davies Ward Phillips & Vineberg LLP until mid-2010 when he took up a position at UWO to teach and undertake research on Canadian tax history.
Lyne Latulippe, Professeure agrégée, École de gestion, Université de Sherbrooke. Prof. Latulippe’s work on the institutional aspects of international taxation development and the conduct of professional tax advisors is widely recognized and influential.

Robert Raizenne, adjunct professor of tax law at McGill Faculty of Law and partner, Osler, Hoskin & Harcourt LLP. Me. Raizenne has extensive experience in a wide variety of tax matters and is a sought-after speaker and writer on national and international tax topics.

This event is free and open to the public.

Tagged as: conference history McGill Tax law

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100 Years of Tax in Canada: McGill Tax Policy Colloquium 2017

Published Sep 05, 2017 - Follow author Allison Christians: - Permalink

2017 marks the centennial of Canada's federal income tax, so it is appropriate that this year’s tax policy colloquium at McGill Law will focus on the theme of 100 Years of Tax Law in Canada. The colloquium is made possible by a grant from Spiegel Sohmer. The land on which we gather is the traditional territory of the Kanien’keha:ka (Mohawk), a place which has long served as a site of meeting and exchange amongst nations.

The distinguished speakers who will contribute to this year’s colloquium include:

  • Kim BrooksProfessor of Law, Dalhousie University. Former Dean, Dalhousie Law, Prof. Brooks is an internationally recognized tax scholar. On October 2, she will present a keynote and take part in a half-day symposium on the history of tax law in Canada.
  • Amir Pichhadze Lecturer, Deakin University, Australia. Prof. Pichhadze is an emerging scholar who studied comparative tax law in the U.S. and U.K. and completed a Judicial Clerkship at the Tax Court of Canada. On October 23, he will present work in progress on the development of value added taxes in Canada, the U.K., and the U.S.
  •  Ajay MehrotraExecutive Director and Research Professor, American Bar Foundation, and Professor of Law, Northwestern University. Professor Mehrotra is a leading voice on tax history in North America who has studied various aspects of interrelationships and influences in Canadian and U.S. tax law history. On November 20, he will present a work in progress on intersecting developments in Canadian and U.S. tax law history. 
  • Ashley StaceyAssociate, Olthuis, Kleer, Townshend. Ms. Stacey is a junior associate whose practice is focused on advising First Nations and First Nation-owned businesses on corporate and commercial transactions and who blogs at oktlaw.com on tax and governance issues relevant to First Nations communities. On December 4, Ms. Stacey will present her work in progress on historical and contemporary intersections of taxation, sovereignty, and autonomy of First Nations in Canada.


The colloquium is open to all.



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Tagged as: colloquium McGill scholarship tax policy

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Update: The Price of Entry: Latest Research plus Infographic

Published Apr 18, 2017 - Follow author Allison Christians: - Permalink



* September update: I've found some more information on Russia's program, which brings it closer to the global averages instead of being a glaring outlier. I've also now uploaded my working paper, Buying in: Residence and Citizenship by Investment, and would welcome comments. Here is the abstract:
States have complex and often conflicted attitudes toward migration and citizenship. These attitudes are not always directly expressed by lawmakers, but they may be reflected quite explicitly in tax regimes: for the world’s most prosperous individuals and their families, multiple states extend a warm welcome. Sometimes prospective migrants are offered fast track to physical residence which can lead to citizenship if the migrant desires it. Others are offered a mere commercial transaction, with citizenship granted to applicants with the right credentials and a willingness to pay. Migrants might seek to obtain residency or citizenship for personal, family, economic, or tax reasons, or some combination of them. For the granting country, the tax significance of obtaining new residents or citizens will vary depending on domestic policy goals. However, the consequences of residence and citizenship by investment programs could be severe for the international tax regime: the jurisdiction to tax and the allocation of taxing rights among countries are commonly based on residence and citizenship factors. This article accordingly surveys contemporary residence and citizenship by investment programs on offer around the world and analyzes their potential impact on international tax policy.

* update: I've found a couple of additional programs (e.g. France has a lower cost program, making it less of an outlier)--thank you twitterverse) and I've corrected a few currency conversion errors. This is still a work in progress as previously noted, and I expect to be revising again in the coming weeks.

----

I've been working on residence and citizenship by investment programs, and thanks to some stellar research assistance by Jake Heyka, have developed a set of data comprising what I believe is a fairly thorough look at the residence and citizenship by investment programs currently on offer around the world. I made the above infographic to show the lowest cost program per country for all countries that offer either residence or citizenship by investment.

The lowest cost residence by investment programs are offered by Panama and Paraguay, each coming in at about USD$5,000, while the most expensive is Russia, at over USD$5 million now Austria, at about $3.3M. The average price for all residence and citizenship by investment programs that we found is about $1 million, but this number isn't perfect because some programs are based on job creation rather than investment (e.g., Portugal, Turkey, UK), some involve having entrepreneur/angel investment support rather than a direct investment (e.g. Australia, Canada), and some involve annual amounts (Italy and Switzerland).

One of the things I wondered about in looking over the programs is the inequality factor at play--that is, how much can richer/larger countries demand in terms of higher prices and more stringent requirements (such as actual residence) for entry, and how much must poorer/smaller countries be satisfied with smaller investments and fewer commitments by the applicant? The answer seems to be that there appears definitely a "rich get richer" quality to the distinctions among programs, but there are lots of details in the programs that require further thought.

The paper itself is still in progress but here is an explanation of what I am looking at:
International law and political theory scholars have long wrestled with the normative implications of commodifying citizenship and access to immigration with pay-to-play visa programs, but the analysis does not typically consider the role the tax system plays or could play in these schemes, nor how such schemes might impact the tax regime in terms of gross revenue or distributional effect.  Yet governments increasingly view their tax systems as a means of potentially increasing the value of residence and citizenship in their countries, whether intrinsically or in relation to the treatment of those who gain such status by other means.  Given the cost involved in reducing revenue from those arguably most able to pay, whether the programs actually produce the predicted outcomes is one obvious question to be asked.  Even if the programs in fact achieve their goals, a second question surely arises regarding the normative justification for using the tax system to lure the wealthy away from other countries in this manner. Does the normative case differ when applied to humans as opposed to companies? Does it differ when the luring state is richer or poorer relative to the countries of origin of prospective immigrants? To sketch out a framework for analyzing these questions requires a sense of the various competing programs on offer. This essay takes the first step by comparing national programs that use their taxing power in some manner in order to attract immigration, and highlights some of the factors that raise normative questions about the appropriate design and uses of a tax system. 
Comments welcome.

Tagged as: migration research tax policy

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The Seven Rules for Tax Research, Now Ten

Published Dec 02, 2016 - Follow author Allison Christians: - Permalink

The OECD released the multilateral instrument (MLI) on tax, so (assuming that at least five countries ratify it), we have to revise the old rules for doing tax research. The MLI means that any given tax situation will be impacted by relevant statutes, relevant tax treaties, and the portions of the MLI that are in effect as to those treaties. So here they are, the revised rules for tax research:




You can find the text of the MLI here. The Explanatory Statement, also at that link, is so far only in English.

Three months after five countries ratify, the MLI will be in effect; subsequent accessions will take effect one month after ratification. However, as to optional provisions, no substantive changes take effect until both parties notify which provisions they intend to apply to which of their treaties. 

The OECD has designed three types of provisions and explains how they relate to existing tax treaties. Here are my notes to self:



Much more analysis to do obviously, but my first cut at this is to try to understand the process of integrating the MLI into the existing tax law order. 

Tagged as: international law MLI OECD research treaties

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How to rob from the poor and give to the rich: Border Tax Equity Act of 2016

Published Nov 07, 2016 - Follow author Allison Christians: - Permalink

In September, Donald Trump started calling for the US to tax imports from Mexico and China etc, on various theories having to do with his vision of what fair trade policy involving the United States would require. Democratic lawmaker Bill Pascrell appears to have seized the moment to re-introduce a bill that has failed multiple times in the U.S. Congress over the years, namely, the so-called Border Tax Equity Act. The idea of this act is simple: tax US consumers on imports and give the money to US companies that export things. If you find it amazing that anyone anywhere could support a tax and redistribute scheme like this, blame it on the pitch: Pascrell (and others) laud this as an answer to what they have characterized as a discriminatory practice, namely the exemption of exported products from value added taxes (VAT) by the 160+ countries that have federal consumption taxes. The argument is that "[t]he disparate treatment of border taxes is arbitrary, inequitable, causes economic distortions based only on the type of tax system used by a country, and is a primary obstacle to more balanced trade relations between the United States and its major trading partners."

This argument is specious and I don't expect the bill to pass but this issue is one that just does not seem like it will go away, I think because it is too easy to pitch the VAT border tax adjustment as "unfair." I had an exchange with trade expert Simon Lester almost ten years ago on this very subject, and re-reading my response today, it seems to cover the bases so I thought I would re-post it. You can see his original post here including a discussion in the comments between myself, Simon, and Sungjoon Cho on the matter. Sungjoon helpfully linked to a GATT working party report from 1970 but his original link is dead, however you can find that report here. Here is what I said (highlights added):

The great fallacy here is that the foreign exporter to the U.S. is somehow subject to no tax while the U.S. exporter is subject to two taxes. This is simply not the case. Other countries, especially our biggest trading partners (e.g. Canada) have both a federal corporate income tax and a federal consumption tax, while the U.S. has only a federal corporate tax. You cannot honestly assess the impact of the VAT in the context of only one country’s corporate income tax, and supporting this legislation this way is dishonest. The Textileworld site you reference conveniently ignores foreign corporate taxes in its analysis—I will leave you to decide for yourself why they might do that.

...I will give a drastically oversimplified example. Assume a U.S. person manufactures a product in the U.S. which it will sell in Canada. The company’s profit on the sale is subject to federal income tax in the U.S., plus VAT in Canada (there called a general sales tax). Let us assume a Canadian company makes a similar product. With the same profit margin as the U.S. company on that product, the big issue here is the different rates of federal corporate taxes each company pays to its home country, because both pay an equal amount of VAT tax in that market. What the export credit in the U.S. would do is lower the U.S . company’s federal income tax burden relative to the Canadian one.

Now flip the scenario, the U.S. manufactures and sells a product in the U.S., where there is no VAT, and the Canadian company manufactures a product in Canada to sell in the U.S. Now each company again will pay its income tax to its home country but what happens to the VAT? Well there is no U.S. federal sales tax, and Canada’s VAT only applies to sales in that market, so the VAT is not imposed on the Canadian product coming in to the U.S.—it is exempt from their VAT. Again, in the U.S. market, there is no price distortion other than the difference in corporate income tax burdens—neither product is subject to VAT. If the U.S. imposes a border tax, I think you might now see that as distortionary (to the extent you believe that a tariff is distortionary in any event). Now you might say yeah, but many states have state sales taxes, wouldn't that equalize the incoming product, exempted from sales (VAT) tax in its foreign country? The answer is, of course, yes. But you don’t see very many people complaining if New York does not impose its sales tax on a product being shipped out of New York for sale in Canada—that is a (much-ignored) direct corollary to the VAT exemption.

I could go on but this argument has been made many times before. I appreciate that tax is complex and there are many alternative taxes and scenarios in which they apply differently, so that it is easy to be swayed by something that “seem unfair.” The bottom line is that people will continue to compare VAT to income taxes when it suits their purposes (i.e., supports protectionist policies like the border tax), and not when it doesn’t (i.e, when they want to pressure a government to lower its corporate tax rate to align with other nations’ corporate tax rate). But don’t be fooled by someone who tries to get you to look at one piece of a complex puzzle and guess what the image is.
Further...
[I]f you seek a level playing field, border taxes and rebates do not achieve that, and in fact, I doubt anyone could ever be confident about how to go about getting it via tax breaks for some and tax penalties for others (I have some ideas about where I would start, but I'll restrain myself). A border tax/rebate does not operate like an inverse VAT or offset an extra cost imposed by a VAT. A border tax is a tariff and a rebate is a subsidy, plain and simple, and I would expect many of our trading partners to oppose it if enacted.

Incidentally, abolishing all income taxes might solve the problem of the income tax competition, but then you have a much different problem. By some estimates, if the U.S. were to abolish the income tax entirely in favor of a sales tax, the rate could be as high as 50%. More likely scenario: we keep the income tax just like it is and ADD a 10-20% federal VAT. This would get rid of the erroneous "VAT as distortion" complaint but I personally would rather keep the debate and take a pass on the VAT.
Today, I am less convinced that the income tax is worth saving and more open to a federal VAT, but that's a discussion for another day. To the above I would only add that in 2009 the US Congressional Research Service undertook a study called International Competitiveness: An Economic Analysis of VAT Border Tax Adjustments, well worth reading--the authors were Maxim Shvedov (now tax policy expert at AARP) and Donald Marples, whose more recent work on inversions with Jane Gravelle is also of interest. Their conclusion:
Economists have long recognized that border tax adjustments have no effect on a nation's competitiveness. Border tax adjustments have been shown to mitigate the double taxation of cross-border transactions and to provide a level playing field for domestic and foreign goods and services. Hence, in the absence of changes to the underlying macroeconomic variables affecting capital flows (for example, interest rates), any changes in the product prices of traded goods and services brought about by border tax adjustments would be immediately offset by exchange-rate adjustments. This is not to say, however, that a nation's tax structure cannot influence patterns of trade or the composition of trade.
In summary: No, taxing at the border for the reasons given does not introduce "equity." It introduces WTO-prohibited tariffs and export subsidies. One could imagine that if the tariffs so raised were used to fund public goods, the possibility for an equitable outcome could be increased. But taking the money out of the pockets of US consumers and putting it in the pocket of US exporters in no way fulfills the stated policy goal.

Tagged as: fairness politics tax policy VAT

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Dataset and research on tax treaties by Martin Hearson and ActionAid

Published Mar 15, 2016 - Follow author Allison Christians: - Permalink

Martin Hearson recently developed an an impressive dataset of tax treaties involving 519 agreements signed from 1970 to 2014 by low and lower-middle income countries in Asia and Sub-Saharan Africa. He prepared this dataset for ActionAid, an NGO that has taken on global tax policy as a development issue. Martin also posted a working paper detailing the methodology used to analyse and score each treaty. Here is the summary:
This paper introduces a new dataset that codes the content of 519 tax treaties signed by low- and lower-middle-income countries in Africa and Asia. Often called Double Taxation Agreements, bilateral tax treaties divide up the right to tax cross-border economic activity between their two signatories. When one of the signatories is a developing country that is predominantly a recipient of foreign investment, the effect of the tax treaty is to impose constraints on its ability to tax inward investors, ostensibly to encourage more investment. 
The merits of tax treaties for developing countries have been challenged in critical legal literature for decades, and studies of whether or not they attract new investment into developing countries give contradictory and inconclusive results. These studies have rarely disaggregated the elements of tax treaties to determine which may be most pertinent to any investment-promoting effect. Meanwhile, as developing countries continue to negotiate, renegotiate, review and terminate tax treaties, comparative data on negotiating histories and outcomes is not easily obtained. 
The new dataset fills both these gaps. Using it, this paper demonstrates how tax treaties are changing over time. The restrictions they impose on the rate of withholding tax developing countries can levy on cross-border payments have intensified since 1970. In contrast, the permanent establishment threshold, which specifies when a foreign company’s profits become taxable in a developing country, has been falling, giving developing countries more opportunity to tax foreign investors. The picture with respect to capital gains tax and other provisions is mixed. As a group, OECD countries appear to be moving towards treaties with developing countries that impose more restrictions on the latter’s taxing rights, while non- OECD countries appear to be allowing developing countries to retain more taxing rights than in the past. These overall trends, however, mask some surprising differences between the positions of individual industrialised and emerging economies. These findings pose more questions than they answer, and it is hoped that this paper and the dataset it accompanies will stimulate new research on tax treaties.
Nadia Harrison and Lovisa Moller produced a report based on the dataset, entitled Mistreated: The tax treaties that are depriving the world’s poorest countries of vital revenue. Here is the abstract:
Women and girls in the world’s poorest countries need good schools and hospitals. To pay for this, these countries urgently need more tax revenue. A little-known mechanism by which countries lose corporate tax revenue is a global network of binding tax treaties between countries. This report marks the release of the ActionAid tax treaties dataset – original research that makes these tax deals made with some of the world’s poorest countries easily comparable and open to public scrutiny.

 ActionAid also produced an interactive map showing overall treaty effects by country.
          These are tremendous resources for anyone studying international tax policy. Bravo to Martin and ActionAid for devoting time and resources to getting this important work out into the world.

          Tagged as: scholarship Tax law tax policy treaties

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          Today at McGill Law: Richard Murphy on the Fair Tax Mark

          Published Nov 02, 2015 - Follow author Allison Christians: - Permalink

          The Spiegel Sohmer Tax Policy Colloquium at McGill University continues today with a presentation by Richard Murphy of Tax Research LLP and the Tax Justice Network, on the Fair Tax Mark. This event is presented in conjunction with a collaborative project between the Stikeman Chair in Taxation and the Centre for Intellectual Property Policy at McGill Law on the topic of how regulation impacts innovation.

          The Fair Tax Mark is a self-regulation project that seeks to intervene in the ongoing relationship between corporations, society, and the state. Like other certifications such as Fair Trade, the Fair Tax Mark is a voluntary program intended to project an image of openness, honesty and trustworthiness in tax matters to consumers and investors. The Mark is about paying taxes, but it is also about dramatically increasing transparency about how multinationals undertake tax planning as a business strategy. This places the payment of tax and the attendant planning and scheming squarely within the realm of corporate social responsibility. The Mark suggests that demonstrating some level of compliance with NGO expectations about global tax justice is becoming a cost of doing business, thus comprising a (or contributing to an existing) social license to operate.

          This year's colloquium focuses on the fundamentals of corporate tax policy by critically examining issues in national and international tax policy; more information about the colloquium here. Today's talk will take place from 14:30-17:30pm in Room 202 of New Chancellor Day Hall, 3644 Peel Ave, Montreal. Students, faculty and the McGill community in Montreal are welcome to attend.

          Tagged as: activism colloquium corporate tax CSR governance McGill tax culture Tax law

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          Mitchell. Murphy. Head to Head Nov 3 in Montreal: Corporate Tax on Trial

          Published Oct 21, 2015 - Follow author Allison Christians: - Permalink


          On Nov 3, there will be a big conference in Montreal on the topic of tax cooperation and competition with presentations by political, business, and academic leaders from around the world; program at the link and I'll post more info soon. A highlight of the day will be a formal debate between Dan Mitchell of the Cato Institute and Richard Murphy of Tax Research UK, on the topic of corporate taxation: continue it, change it, abolish it? These two titans will debate three resolutions:
          1. First, be it resolved that: the current approach to corporate taxation is a necessary and appropriate means of raising tax revenue.
          2. Second, be it resolved that: corporate taxation is fundamental to preserve personal taxation.
          3. Third, be it resolved that: To the extent that governments tax corporate income, they should do so comprehensively, and not use tax incentives to favour selected types of investment or commerce.
          It likely goes without saying that arguing on the “affirming side” of each resolution will be Richard Murphy; arguing on the “opposing side” of each resolution will be Dan Mitchell; the debaters are free to interpret the resolutions broadly and form their arguments accordingly. Evidence from all jurisdictions will be admissible. The debate will be moderated and judged by two eminent judges: Louise Otis (OECD Admin Tribunal & McGill Law) and Jay Rosengard (Harvard Kennedy School of Business). The emphasis will be on persuasive, clear and logical argumentation. This promises to be a lively debate. Registration information for the conference is here.

          Tagged as: conference corporate tax Tax law tax policy

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          Cockfield: Big Data and Tax Haven Secrecy

          Published Oct 14, 2015 - Follow author Allison Christians: - Permalink

          Art Cockfield has posted a new paper on SSRN, Big Data and Tax Haven Secrecy, forthcoming Florida Tax Review. The article sets out research he did with the International Consortium of Investigative Journalists (ICIJ) and is of interest. Here is the abstract:

          While there is now a significant literature in law, politics, economics, and other disciplines that examines tax havens, there is little information on what tax haven intermediaries — so-called offshore service providers — actually do to facilitate offshore evasion, international money laundering and the financing of global terrorism. To provide insight into this secret world of tax havens, this Article relies on the author’s study of big data derived from the financial data leak obtained by the International Consortium for Investigative Journalists (ICIJ). A hypothetical involving Breaking Bad’s Walter White is used to explain how offshore service providers facilitate global financial crimes. The Article deploys a transaction cost perspective to assist in understanding the information and incentive problems revealed by the ICIJ data leak, including how tax haven secrecy enables elites in non-democratic countries to transfer their monies for ultimate investment in stable democratic countries. The approach also emphasizes how, even in a world of perfect information, political incentives persist that thwart cooperative efforts to inhibit global financial crimes.

          Tagged as: evasion information scholarship tax policy

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          Spiegel Sohmer Tax Policy Colloquium at McGill Law

          Published Sep 28, 2015 - Follow author Allison Christians: - Permalink

          McGill Law's annual Speigel Sohmer Tax Policy Colloquium kicks off today with a presentation by Roseanne Altshuler on the viability of a switch from worldwide to territorial corporate taxation in the United States. This year's colloquium will focus on the fundamentals of corporate tax policy by critically examining issues in national and international tax policy. Today's talk will take place from 14:30-17:30pm in Room 202 of New Chancellor Day Hall, 3644 Peel Ave, Montreal. Students, faculty and the McGill community in Montreal are welcome to attend.

          Here is the colloquium line-up for the fall:

          Monday, September 28: Rosanne Altshuler

          Rosanne Altshuler is Dean of Social and Behavioral Science and a Professor of Economics at Rutgers University. She was the Chair of the Department of Economics at Rutgers from 2011 to 2015. She has written widely on federal tax policy, including her most recent article “Lessons the United States Can Learn from Other Countries’ Territorial Systems for Taxing Income of Multinational Corporations.”

          Monday, October 5: Steven Dean

          Steven Dean is a Professor at Brooklyn Law School and a specialist in tax law. His research addresses a range of tax and budgetary issues, including unconventional solutions to problems such as tax havens, regulatory complexity and tax shelters. His recent article, “Tax Deregulation,” considered the surprising implications of enhancing taxpayer autonomy.

          Monday, November 2: Richard Murphy

          Richard Murphy is a chartered accountant and economist. He is the founder of the Tax Justice Network and the director of Tax Research LLP, which undertakes work on tax policy, advocacy and research. Mr. Murphy is the co-author of several publications on tax policy, including his most recent book, “Over Here and Undertaxed: Multinationals, Tax Avoidance and You.”

          Tuesday, November 10: Daniel N. Shaviro

          Daniel Shaviro is a Professor of Taxation at the New York University School of Law. Professor Shaviro has written several books examining tax policy, budget policy and entitlements issues. His most recent book, “Fixing US International Taxation,” offers an analytical framework for international tax policy that sidesteps the standard worldwide taxation vs. territorial taxation framework.

          Monday, November 23: Kim Brooks

          Kim Brooks is Dean and Weldon Professor of Law at the Schulich School of Law, Dalhousie University. Dean Brooks’ research focuses on corporate and international tax law and policy. She focuses on using a discrete area of tax law to understand a larger tax concept, and using the tax system to promote international economic justice. Dean Brooks has written widely on tax treaties and international taxation, including her recent chapter, “The Troubling Role of Tax Treaties” in the volume 51 of “Tax Design Issues Worldwide: A Series on International Taxation.”

          Monday, November 30: Albert Baker

          Albert Baker is the Global Leader in Tax Policy at Deloitte & Touche LLP, where he specializes in international tax, including mergers and acquisitions, corporate financing and corporate reorganizations. His recent research focuses on base erosion & profit shifting, a project to address concerns that current international tax frameworks result in double non-taxation, or stateless income, or reducing the tax base in high tax countries.

          The Spiegel Sohmer Tax Policy Colloquium has been made possible by a generous grant from the law firm Spiegel Sohmer, Inc., Montreal, for the purpose of fostering an academic community in which learning and scholarship may flourish. I am delighted to welcome these distinguished guests and look forward to today's discussion.

          Tagged as: colloquium corporate tax McGill scholarship tax policy

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