Chapter 8: Canada: Judicial Review of Taxpayer’s Request for Competent Authority Assistance under Canada-United States Tax Treaty

Why this book? This book provides a unique and comprehensive global overview of international tax disputes on double tax conventions, thereby filling a gap in the area of tax treaty case law. It covers the 39 most important tax treaty cases that were decided in 2013 around the world. The systematic structure of each case allows easy and efficient comparison of the varying application and interpretation of tax treaties in different regimes. With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2014 is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational enterprises, policymakers, tax administrators, judges and academics. Downloads Sample excerpt, including table of contents This book is part of the Tax Treaty Case Law around the Globe Series View other titles in the series Editor(s) Eric Kemmeren, professor of international tax law and international taxation at and chairman of the Tax Economics Department of the Fiscal Institute Tilburg of Tilburg University, the Netherlands and member of the board of the European Tax College. Daniël Smit, Ph.D. in international tax law and European taxation at the Fiscal Institute Tilburg of Tilburg University, the Netherlands. Peter Essers, professor of tax law at and chairman of the Tax Law Department of the Fiscal Institute Tilburg of Tilburg University, the Netherlands and member of the board of the European Tax College. Michael Lang, professor at and head of the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business). Jeffrey Owens, professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business) and head of the Global Tax Policy Center at the Institute for Austrian and International Tax Law, WU. Pasquale Pistone, professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business); associate professor at the University of Salerno, Italy and Academic Chairman IBFD. Alexander Rust, professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business). Josef Schuch, professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business). Claus Staringer, professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business). Alfred Storck, professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business). Contributor(s) Philip Baker, Tomas Balco, Cédric Ballenegger, Martin Berglund, Stefano Bernasconi, Michael Beusch, Yariv Brauner, José Manuel Calderón Carrero, Graeme Cooper, Tsilly Dagan, Luc De Broe, César Augusto Domínguez Crespo, David Duff, Kasper Dziurdź, Søren Friis Hansen, Marjaana Helminen, Eric C.C.M. Kemmeren, Patrick Knörzer, Michael Lang, Guglielmo Maisto, Alexandre Maitrot de la Motte, Adolfo Martín Jiménez, Danuše Nerudová, João Nogueira, Alexander Rust, Jacques Sasseville, Dikshit Prasad Sengupta, Daniël Smit, Alfred Storck, Danil Vladimirovich Vinnitskiy, Martin Wenz, Billur Yalti, Salome Zimmermann.

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