2021 Lectureship Series Archive

Corporate Residence, Legal Fictions and Tax Jurisdiction     

The concept of ‘residence’ of a corporation is a cornerstone of corporate income taxation in domestic and international law. This Lecture discusses corporate residence in its historical context and in light of Australian and international case law, as well as the recent Australian proposal to provide that a company incorporated offshore will be treated as an Australian tax resident if it has a “significant economic connection to Australia”. The proposal appears aimed at establishing economic substance in a legal world in which fictions are layered on fictions. It then explores the function of the legal definition of residence for corporations in establishing tax jurisdiction. This question is inextricably linked to the purpose of the corporate tax in a global era, that may be fundamentally changed by the OECD/G20 BEPS initiative as well as the covid-19 pandemic.

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For Alberta lawyers, consider including this webinar as a CPD learning activity in your mandatory annual Continuing Professional Development Plan as required by the Law Society of Alberta. The Law Society of Alberta does not accredit courses offered by CLE providers nor assign hours to a course. It is the decision of each lawyer whether a CPD course or activity meets the requirements of Rule 67.1 and whether to include it in their CPD Plan.

This webinar has been approved by the Law Society of British Columbia for up to 2.5 CPD credits. At the conclusion of the webinar, you can click here to log-in to the Law Society of British Columbia’s website to register your credits. This webinar will be listed under the event name “IFA Canada Lectureship Series: Corporate Residence, Legal Fictions and Tax Jurisdiction”.

This webinar may be reported for up to 2.5 hours of eligible CPD activity. The Law Society of Manitoba does not accredit providers, but will have the discretion to determine that activities offered by a specific provider are not eligible activities if they do not adequately promote competent practice. It is up to the lawyer to determine if the activity is an eligible CPD activity.

This program has been approved by the Law Society of New Brunswick for up to 2.5 CPD credits. Lawyers are required to self-report their CPD activities in their Member Profile through the Law Society’s website.

For Nova Scotia lawyers, consider including this webinar as a CPD learning activity in your mandatory annual Continuing Professional Development Plan as required by the Nova Scotia Barristers’ Society. The Society does not accredit courses offered by CLE providers nor assign hours to a course. It is the decision of each lawyer whether a CPD course or activity meets the requirements of Regulation 8.3.3 and whether to include it in their CPD Plan.

This webinar is eligible for up to 2.5 Substantive Hours. According to the Law Society of Ontario, substantive hours may address substantive or procedural law topics and/or law related subjects that are relevant to the lawyer’s or paralegal’s practice and professional development.

We have submitted this webinar for approval by the Barreau du Québec for up to 2.5 hours of professional development. Approval for this event may still be pending or may now be approved.

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This program has been approved by the Law Society of Saskatchewan for up to 3 CPD hours. Lawyers are required to self-report their CPD activities in their Member Profile through the Law Society’s website.