The Resource A balancing Act : the interplay between treaty tiebreaker rules and Canadian tax law - Black v. The Queen : 2014 TCC 12

A balancing Act : the interplay between treaty tiebreaker rules and Canadian tax law - Black v. The Queen : 2014 TCC 12

Label
A balancing Act : the interplay between treaty tiebreaker rules and Canadian tax law - Black v. The Queen : 2014 TCC 12
Title
A balancing Act : the interplay between treaty tiebreaker rules and Canadian tax law - Black v. The Queen : 2014 TCC 12
Creator
Subject
Language
eng
Summary
The Tax Court of Canada's decision in Black v. The Queen deals with the broad question of the interaction between domestic tax law and tax treaties (or conventions) where there is a perceived "inconsistency" between the two. An individual can be resident of more than one state or jurisdiction for the purposes of each state's domestic tax rules. Canada's bilateral income tax conventions contain tiebreaker rules to provide that an individual will be resident in only one of the contracting states for the purposes of the applicable convention
Citation source
In: Canadian tax journal = Revue fiscale canadienne. - Toronto. - Vol. 62 (2014), no. 2 ; p. 477-483
http://library.link/vocab/creatorName
Al-Shikarchy, M
Language note
English
http://library.link/vocab/subjectName
  • case law
  • residence
  • non-resident
  • dual residence
  • tax treaty
  • domestic tax law
  • tie-breaker rule
Label
A balancing Act : the interplay between treaty tiebreaker rules and Canadian tax law - Black v. The Queen : 2014 TCC 12
Instantiates
Publication
Label
A balancing Act : the interplay between treaty tiebreaker rules and Canadian tax law - Black v. The Queen : 2014 TCC 12
Publication

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