Anmerkungen:
In: Income Tax at 100 Years: Essays and Reflections on the Income War Tax Act, Canadian Tax Foundation, 2017, ISBN: 978-0-88808-298-5
Nach Informationen von SSRN wurde die ursprüngliche Fassung des Dokuments October 1, 2017 erstellt
Beschreibung:
This paper examines one of the most important, and often poorly analyzed, concepts – source of income. It traces the evolution of this concept in Canada and offers insights on the implications of the G20/OECD BEPS project (which, in effect, created some “negative” source rules for business profits). The paper claims that the source of income is fundamentally a legal notion, serving a primary jurisdictional function. The core notion of source implies that Canada sees itself as a co-venturer with taxpayers in earning income. Because of the changes in how income is earned, the paper suggests that the notion of source may need to be re-conceptualized