Corporate Residence and International Taxation


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The taxation of incorporated companies on the residence principle raises difficult legal, theoretical and practical issues. In this book, the author analyses the case law test for corporate residence, developed mainly in the United Kingdom beginning in the 19th century, the residence definition adopted in the OECD Model Convention and some of its more common variants, and Canadian domestic statutory provisions. The case law sense is viewed in historical context, as a result of the then emerging conception of corporate personality and the statutory requirements of income tax law. Practical difficulties or ambiguities in the tax treaties are examined and Canadian statutory modifications of the corporate residence test considered as a paradigm for legislative reaction to the judicial and tax treaty rules.

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