Why this book?

The international tax system is premised on the distinction between residence and source taxation. From both a policy and a practical perspective, the residence taxation of incorporated companies has never been entirely satisfactory. The application of the English case law test, the OECD Model residence definition and domestic statutory provisions are all considered in this book.

The aim of the book is to discover what is meant by corporate residence, how and why the concept is developed in case law of the United Kingdom, and how it is used today in income tax conventions and in Canadian domestic income tax law.

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Author(s)

Robert Couzin was educated at the University of Chicago and McGill University. He is a lawyer and leader of Canadian income tax consulting for Ernst & Young. Mr. Couzin is one of Canada’s leading tax practitioners and has published numerous articles on corporate and international tax matters.