Residence of Companies Under Tax Treaties and EU Law (Canada)

RESIDENCE OF COMPANIES UNDER TAX TREATIES AND EC LAW, Guglielmo Maisto, ed., pp. 407-440, Amsterdam: IBFD, 2009

23 Pages Posted: 15 Jul 2009 Last revised: 7 Dec 2009

See all articles by Kim Brooks

Kim Brooks

Dalhousie University - Schulich School of Law

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Date Written: July 15, 2009

Abstract

This chapter reviews the development and present Canadian law on the residence of corporations for tax purposes. It highlights a few of the elements of Canada's corporate law regime by way of context; outlines why residence matters to corporations for Canadian tax purposes, traces the history of the Canadian tests for corporate residence, explains how the Canadian Income Tax Act addresses continuances, and reviews the approach to the determination of corporate residence reflected in Canada's tax treaties.

Keywords: corporate tax, tax policy, taxation

JEL Classification: K00

Suggested Citation

Brooks, Kimberley, Residence of Companies Under Tax Treaties and EU Law (Canada) (July 15, 2009). RESIDENCE OF COMPANIES UNDER TAX TREATIES AND EC LAW, Guglielmo Maisto, ed., pp. 407-440, Amsterdam: IBFD, 2009, Available at SSRN: https://ssrn.com/abstract=1434531

Kimberley Brooks (Contact Author)

Dalhousie University - Schulich School of Law ( email )

6061 University Ave
Weldon Law Building
Halifax, Nova Scotia B3H4H9
Canada

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