Tag: Vern Krishna

GAAR and Tax Treaties

Tax avoidance, a concept increasingly familiar to most developed countries, has assumed dominant presence in international taxation. The subject was the focus of the…  Read more

The Westminster Principle

The law says that a taxpayer is entitled to legally arrange her affairs to mitigate tax. Tax planning involves analysis of legislation and its…  Read more

Treaty Shopping and Tax Avoidance

Agreements for the avoidance of double taxation are bilateral Conventions (herein, sometimes referred to as “treaties”) between sovereign States. The personal scope article of…  Read more

The Revenue Rule in Tax Law

 A country’s revenue laws reflect its political sovereignty and create property rights that affect relationships. Hence, sovereign states will not enforce the revenue laws…  Read more

He Who Writes the Rules Will Win

The Department of Finance’s consultation paper in which it outlines various proposals to bolster the General Anti-avoidance Rule (“GAAR”) in section 245 against taxpayers…  Read more

Red Flags for Tax Audits

Millions of employees forced to work from home because of COVID-19 turned their bedrooms, basements, and kitchens into workspaces. In doing so, they took…  Read more