2007 Lectureship Materials

INTERNATIONAL FISCAL ASSOCIATION
(Canadian Branch)

2007 Traveling Lectureship Program
THE CANADIAN FOREIGN AFFILIATE SYSTEM:
ARE THE SURPLUS RULES SURPLUS?

FACULTY
J. Scott WilkieOsler, Hoskin & Harcourt LLP

Nick Pantaleo, FCA
PricewaterhouseCoopers LLP

INDEX OF READING MATERIALS

1.	Introduction

2.	The Foreign Affiliate System in View and Review, by J. Scott Wilkie, Robert Raizenne, Heather I. Kerr, and Angelo Nikolakakis (Canadian Tax Foundation, 1993 Corporate Management Tax Conference)

3.	Taxing Foreign Business Income, by Nick Pantaleo and J. Scott Wilkie (Canadian Tax Foundation, 1998 Corporate Management Tax Conference)

4.	Royal Commission on Taxation (“Carter Commission”), Excerpts, Chapter 26, International Aspects of Income Taxation

5.	R. Alan Short, Report 1967 (April) Conference on the Report of The Royal Commission on Taxation, Canadian Tax Foundation

6.	R. Alan Short, “International Tax Provisions”, International Aspects I, Canadian Tax Foundation, Twenty-Second Tax Conference, 1970

7.	House of Commons, Minutes of Proceedings and Evidence of the Standing Committee on Public Accounts, December 8 and 10, 1992, Excerpts

8.	International Taxation, Report of the Technical Committee on Business Taxation (1997, the “Mintz Committee”)

9.	2001 International Tax Seminar (Calgary), Learning the Ropes for Going Global, Canadian Tax Foundation

10.	International Tax Policy Directions: Some Thoughts on Recent Canadian Experience, by J. Scott Wilkie and Robert Raizenne (Canadian Tax Foundation Annual Conference, 1997)

11.	Unlinking Tax Treaties and the Foreign Affiliate Rules: A Modest Proposal, by Brian J. Arnold (Canadian Tax Journal, 2002)

12.	Exempt Surplus: What’s the Problem? A Reply to Brian Arnold, by Angelo Nikolakakis (Canadian Tax Journal, 2002)

13.	The Joint Committee on Taxation of The Canadian Bar Association and The Canadian Institute of Chartered Accountants – Letters

14.	Proposed Subsection 88(3), Tax Legislation Division Tax Policy Branch – “Comfort Letters”

15.	United States, The President’s Advisory Panel on Federal Tax Reform, 2005, Excerpts Regarding International Taxation

16.	The Tax Lawyer, Vol. 59, No. 3, Spring 2006 – Report of the American Bar Association Tax Section Task Force on International Tax Reform (2006)

17.	Australian Government, Abstracts Concerning International Taxation Reform

18.	New Zealand International Tax Review: A Direction For Change, A Government Discussion Document

19.	From the Bottom Up: Taxing the Income of Foreign Controlled Corporations, by H. David Rosenbloom, Brooklyn Journal of International Law (2001)

20.	Why Not Des Moines? A Fresh Entry in the Subpart F Debate, by H. David Rosenbloom (Tax Notes International, 2003)

21.	Throw Territorial Taxation From the Train, by Edward D. Kleinbard

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2007 Lectureship Materials

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