A Few Thoughts on Treaty Shopping

Robert Couzin ()
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Robert Couzin: Couzin Taylor LLP, Toronto

Canadian Tax Journal, 2013, vol. 61, issue 3, 671-676

Abstract: The author provides some brief and immediate reactions to the Department of Finance's consultation paper on treaty shopping. These concern certain tax policy issues: the quantification of revenue loss, which implies some normative assumptions; the relevance of the residence of the owner to claims of treaty benefits by a corporation; the role of corporate "substance"; and the distinction between back-to-back conduit arrangements and other possible forms of treaty abuse. The author concludes that policy makers should pay closer attention to the basic principles relating to issues such as these before they focus on the mechanics of a solution.

Keywords: Treaty shopping; policy; tax law (search for similar items in EconPapers)
Date: 2013
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