IFA CANADA LECTURESHIP SERIES
THURSDAY, FEBRUARY 18, 2021
3:30PM – 6:30PM EASTERN / 12:30PM – 3:30PM PACIFIC
Corporate Residence, Legal Fictions and Tax Jurisdiction
The concept of ‘residence’ of a corporation is a cornerstone of corporate income taxation in domestic and international law. This Lecture discusses corporate residence in its historical context and in light of Australian and international case law, as well as the recent Australian proposal to provide that a company incorporated offshore will be treated as an Australian tax resident if it has a “significant economic connection to Australia”. The proposal appears aimed at establishing economic substance in a legal world in which fictions are layered on fictions. It then explores the function of the legal definition of residence for corporations in establishing tax jurisdiction. This question is inextricably linked to the purpose of the corporate tax in a global era, that may be fundamentally changed by the OECD/G20 BEPS initiative as well as the covid-19 pandemic.
Guest Lecturer:
Professor Miranda Stewart, Melbourne Law School, University of Melbourne, Honorary Professor, Australian National University
With discussant Professor Jinyan Li, Co-director, LLM Tax Program, Osgoode Hall Law School, York
Email [email protected] with any questions.
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