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Stock lending -beneficial ownership and tax avoidance- again! (Kluwer International Tax Blog)
: Although the meaning of beneficial ownership in tax treaties first burst onto the scene in Indofood International Finance Ltd v JP Morgan Chase Bank N.A. London Branch [2006] EWCA Civ 158 and, for the first time in Canada in Prévost Car Inc. v R 2008 TCC 231, (affirmed 2009 FCA 57), its meaning and application... Continue
The U.S. pushback on minimum corporate tax rates may test the limits of bilateral tax treaties with EU Member States (Kluwer International Tax Blog)
: *This post was first published on the website of Maastricht University* In recent weeks the tax world gave a lot of attention to how President Trump blew up some serious advancements in international tax law, long in the making. One of those advancements was the introduction of a minimum tax on profits of the... Continue