Canadian Tax Journal/Revue fiscale canadienne最新文献_第9页

Policy Forum: In Defence of the First Nations Fiscal Management Act 政策论坛:捍卫第一民族财政管理法

Canadian Tax Journal/Revue fiscale canadienne Pub Date : 2021-11-01 DOI: 10.32721/ctj.2021.69.3.pf.ledressay

André Le Dressay

引用次数: 1

Policy Forum: Editors' Introduction—First Nation Property Taxation 政策论坛:编者导论——国家财产税

Canadian Tax Journal/Revue fiscale canadienne Pub Date : 2021-11-01 DOI: 10.32721/ctj.2021.69.3.pf.editors

Frances R. Woolley, R. Doxtator, A. Macnaughton

引用次数: 1

Income Tax Complexity Faced by Multinational Corporations: A Comparative Study of Canada, the United States, and Other Selected OECD Countries 跨国公司面临的所得税复杂性:加拿大、美国和其他经合组织国家的比较研究

Canadian Tax Journal/Revue fiscale canadienne Pub Date : 2021-11-01 DOI: 10.32721/ctj.2021.69.3.sturm

Susan P. Sturm

引用次数: 0

Corporate Tax Planning: Impact of COVID-19 and Transfer Pricing: Approaches for Comparability Adjustments 企业税收筹划:新冠肺炎疫情的影响与转让定价:可比性调整方法

Canadian Tax Journal/Revue fiscale canadienne Pub Date : 2021-11-01 DOI: 10.32721/ctj.2021.69.3.ctp

Andrew Barton, Vinu Subramaniam, Paola Marino

{"title":"Corporate Tax Planning: Impact of COVID-19 and Transfer Pricing: Approaches for Comparability Adjustments","authors":"Andrew Barton, Vinu Subramaniam, Paola Marino","doi":"10.32721/ctj.2021.69.3.ctp","DOIUrl":"https://doi.org/10.32721/ctj.2021.69.3.ctp","url":null,"abstract":"The impact of the COVID-19 pandemic has varied significantly across market sectors and companies, and the disruptions generated by the pandemic have had major implications for the transfer-pricing practices of many multinationals. The COVID-19 crisis has challenged the efficiency of traditional benchmarking of profit margins and markups on the basis of the profitability of comparable companies. In this article, we provide a framework for addressing two key questions: (1) how to ensure that the data used for setting or testing transfer-pricing results are appropriate in terms of comparability and that they adequately reflect economic reality for the tested party; and (2) what adjustments need to be made if the tested party's results fall below the arm's-length range. Given the extraordinary circumstances, we cannot rely on a simple analysis of historical data to adjust for the impact faced by businesses as a result of COVID-19. For example, in situations where the taxpayer's results have been affected by the COVID-19 pandemic to a greater extent than the results of comparable companies, the approaches outlined in this article will provide the taxpayer with an estimated arm's-length range of profitability for the comparable companies that is calibrated to the impact of the pandemic on the tested party's results. These approaches are aligned with the transfer-pricing guidance for COVID-19 adjustments issued by the Organisation for Economic Co-operation and Development in December 2020.","PeriodicalId":375948,"journal":{"name":"Canadian Tax Journal/Revue fiscale canadienne","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2021-11-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"115686981","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

引用次数: 1

Policy Forum: Establishing an Urban Reserve—Property Tax Challenges and Opportunities 政策论坛:建立城市储备房产税的挑战与机遇

Canadian Tax Journal/Revue fiscale canadienne Pub Date : 2021-11-01 DOI: 10.32721/ctj.2021.69.3.pf.icton

Mike Icton, Devan Mescall

{"title":"Policy Forum: Establishing an Urban Reserve—Property Tax Challenges and Opportunities","authors":"Mike Icton, Devan Mescall","doi":"10.32721/ctj.2021.69.3.pf.icton","DOIUrl":"https://doi.org/10.32721/ctj.2021.69.3.pf.icton","url":null,"abstract":"Urban reserves offer a unique economic development tool for First Nation governments by providing access to markets and infrastructure unavailable on most reserve lands in Canada. Asimakiniseekan Askiy is Canada's first urban reserve established on land previously owned by a city. The urban reserve was established in Saskatoon by the Muskeg Lake Cree Nation in 1988. Asimakiniseekan Askiy provides an example of the economic potential of urban reserves for First Nations and their members, as well as municipal governments and their citizens. The urban reserve is currently home to 60 First Nation and non-First Nation businesses and their 700 employees. In 2020, the urban reserve contributed $465,662 to the city of Saskatoon in service fee payments. However, before this economic potential could be realized, property taxation presented a sizable barrier in the path of taking Asimakiniseekan Askiy from an innovative idea to a successful reality. Establishing an urban reserve has significant property tax implications, since the process requires the transfer of property from the taxing authority of a municipal jurisdiction to the tax jurisdiction of a First Nation government. Agreements providing for the transfer of tax authority also include negotiations relating to the continued provision of services to the urban reserve by the municipality. This article first provides a summary of the statutory environment surrounding the formation and taxation of an urban reserve. A case study of the establishment and 33 years of operation of Asimakiniseekan Askiy is then provided, to illustrate the property tax implications and municipal service agreement process necessary for Canadian communities to achieve the economic benefits of urban reserves. The authors identify property tax challenges inherent in the establishment of an urban reserve and offer recommendations to improve access to urban reserves as an innovative economic development tool.","PeriodicalId":375948,"journal":{"name":"Canadian Tax Journal/Revue fiscale canadienne","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2021-11-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"125891088","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

引用次数: 1

Policy Forum: Implementing the Chippewas of Georgina Island First Nation Property Tax System—Opportunities, Challenges, and Lessons Learned 政策论坛:实施乔治亚岛第一民族房产税制度的示范——机遇、挑战和经验教训

Canadian Tax Journal/Revue fiscale canadienne Pub Date : 2021-11-01 DOI: 10.32721/ctj.2021.69.3.pf.mccue

Kate McCue, Billy McCue

{"title":"Policy Forum: Implementing the Chippewas of Georgina Island First Nation Property Tax System—Opportunities, Challenges, and Lessons Learned","authors":"Kate McCue, Billy McCue","doi":"10.32721/ctj.2021.69.3.pf.mccue","DOIUrl":"https://doi.org/10.32721/ctj.2021.69.3.pf.mccue","url":null,"abstract":"In 2018, the Chippewas of Georgina Island First Nation (GIFN) implemented a First Nation property tax system under the First Nations Fiscal Management Act (FMA)—one of the earliest First Nations in Ontario to do so. Implementation of a property tax system gave GIFN an opportunity to improve funding for and expand local services, and provide a more equitable sharing of local service costs between cottagers leasing First Nation land and the First Nation. Key challenges encountered when implementing the property tax system were building consensus around the need for a tax system, building an appropriate administrative infrastructure, carrying out property assessments, and professionals lacking knowledge of First Nation property tax. These challenges, however, presented opportunities to create a knowledge base around property taxation within GIFN, among cottage leaseholders, and in the wider community. Key lessons learned were (1) start as soon as possible; (2) First Nations Tax Commission support and standards are important; (3) staff training is important; (4) communicate early and often; (5) hold open houses; (6) local services are more than garbage collection; (7) property taxes do not harm lease rates or cottage sales; (8) educate lawyers, real estate agents, and other professionals; (9) startup costs were significant; (10) coordinate laws and standards with provincial variations; (11) modernize systems; and (12) utilize other parts of the FMA.","PeriodicalId":375948,"journal":{"name":"Canadian Tax Journal/Revue fiscale canadienne","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2021-11-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"133516473","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

引用次数: 0

Selected US Tax Developments: Adams Challenge (UK) Limited: When Does a Treaty Provision Conflict with the Code? 美国税收发展:亚当斯挑战(英国)有限公司:条约条款何时与法典发生冲突?

Canadian Tax Journal/Revue fiscale canadienne Pub Date : 2021-08-01 DOI: 10.32721/ctj.2021.69.2.ustd

Michael J. Miller

引用次数: 0

Policy Forum: Future Workforce Models—Enabling the Shift 政策论坛:未来劳动力模式——实现转变

Canadian Tax Journal/Revue fiscale canadienne Pub Date : 2021-08-01 DOI: 10.32721/ctj.2021.69.2.pf.jason

Guy Jason, Shivani Joshi

引用次数: 0

Corporate Income Shifting in an Era of Tax Multilateralism: The Impact of Exchange-of-Information Agreements 税收多边时代的企业收入转移:信息交换协议的影响

Canadian Tax Journal/Revue fiscale canadienne Pub Date : 2021-08-01 DOI: 10.32721/ctj.2021.69.2.mescall

Devan Mescall, Paul Nielsen

{"title":"Corporate Income Shifting in an Era of Tax Multilateralism: The Impact of Exchange-of-Information Agreements","authors":"Devan Mescall, Paul Nielsen","doi":"10.32721/ctj.2021.69.2.mescall","DOIUrl":"https://doi.org/10.32721/ctj.2021.69.2.mescall","url":null,"abstract":"Using data from the annual reports of over 100,000 subsidiaries of multinational enterprises (MNEs) from 55 countries between 2003 and 2012, the authors of this article investigate the impact of exchange-of-information agreements (\"EOI agreements\") on tax-motivated income shifting. Transparency created by the signing of EOI agreements is expected to reduce the tax-motivated shifting of income by multinational corporations. Whether such agreements affect the income-shifting behaviour of multinational corporations is an unanswered question. The authors find evidence that, on average, EOI agreements do have an impact on tax-motivated income shifting. Additionally, they find that more advanced, modern EOI agreements are associated with a larger decrease in tax-motivated income shifting compared to the impact of early EOI agreements. This evidence challenges the prevalent assumption in empirical studies that EOI agreements are homogeneous. Supplemental analyses suggest that factors that affect the information asymmetry between MNEs and tax authorities, such as corporations with high levels of intangibles and tax authorities with strong transfer-pricing rules and enforcement, can diminish or enhance the effectiveness of EOI agreements in moderating tax-motivated income shifting. The evidence provided by this study shows that consideration of the tax authorities' information environment and the substance of an EOI agreement is essential when assessing the impact of such an agreement on the tax behaviour of sophisticated taxpayers such as multinational corporations.","PeriodicalId":375948,"journal":{"name":"Canadian Tax Journal/Revue fiscale canadienne","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2021-08-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"130832196","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

引用次数: 1

Planification fiscale personnelle : Les enjeux actuels de la rémunération 个人税务筹划:当前薪酬问题

Canadian Tax Journal/Revue fiscale canadienne Pub Date : 2021-08-01 DOI: 10.32721/ctj.2021.69.2.pfp

Ana-Luiza Georgescu

引用次数: 0