residence

Treaty-shopping is not Inherently Abusive Tax Avoidance in Canada v Alta Energy Luxembourg S.A.R.L.

In Canada v Alta Energy Luxembourg S.A.R.L., 2021 SCC 49 [Alta Energy], the Supreme Court of Canada (“SCC”) unanimously held that taxpayers are entitled to arrange their affairs under international tax treaties to minimize their  liability. These arrangements – also referred to as ‘treaty-shopping’ –  will not necessarily be considered abusive unless the absence of […]

One Million Potential New Voters: Frank v Canada (Attorney General)

Introduction As the country prepares for a federal election later this year, approximately one million additional citizens will have the right to cast special ballots. In Frank v Canada (Attorney General) 2019 SCC 1 [Frank], the Supreme Court of Canada ["SCC" or “the Court”] struck down provisions of the Canada Elections Act SC 2000, c […]