The Resource Shades of gray : Conrad Black's international tax gambit

Shades of gray : Conrad Black's international tax gambit

Label
Shades of gray : Conrad Black's international tax gambit
Title
Shades of gray : Conrad Black's international tax gambit
Creator
Subject
Language
eng
Summary
This article looks at a case involving Conrad Black in which the interplay of treaty and domestic rules regarding jurisdiction to tax was explored. In a judgment released on 20 January 2014, the Tax Court of Canada ruled that residual Canadian jurisdiction to tax persons resident in Canada for domestic law purposes was not supplanted by a treaty tie-breaker rule that resulted in Black being resident only in the United Kingdom for purposes of the Canada-U.K. tax treaty. Although based on the provisions of the treaty and Canadian law in force at the time, Black v. The Queen, 2014 TCC 12, grapples with issues relevant in other jurisdictions involving the interplay of treaty and domestic rules regarding jurisdiction to tax in an attempt to arbitrage two different domestic tax systems
Citation source
In: Tax notes international. - Falls Church. - Vol. 74 (2014),
http://library.link/vocab/creatorName
  • Milet, M
  • Ford, S
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • case law
  • tax treaty
  • residence
  • tie-breaker rule
  • domestic tax law
Label
Shades of gray : Conrad Black's international tax gambit
Instantiates
Publication
Label
Shades of gray : Conrad Black's international tax gambit
Publication

Library Locations

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      52.3736660 4.9336932
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