2024 IFA Canada Travelling Lectureship

Around the Global Minimum Tax in 180 Minutes​

Guest Lecturer:
Heydon Wardell-Burrus
, Senior Advisor, International Co-operation and Tax Administration Centre for Tax Policy and Administration, OECD

Brian Ernewein
, Senior Advisor, National Tax KPMG in Canada

The global minimum tax seeks to stabilize the international tax system by addressing tax avoidance and tax competition. This lecture will address its origins, how it achieves those aims and its interactions with existing pieces of international tax infrastructure including tax incentives, cross-border taxes (including withholding taxes and CFC taxes such as the US GILTI regime), tax treaties and investment agreements. Finally, the lecture will address what we may expect from the future in this area.

2024 Lectureship Dates

This will be a fully in-person event. There will not be a virtual option.

TORONTO  |  JANUARY 24, 2024

9:00 AM – 12:30 PM EST

Ivey Donald K. Johnson Centre
130 King St W, Toronto

OTTAWA  |  JANUARY 25, 2024

9:00 AM – 12:30 PM  EST

Sheraton Ottawa Hotel
150 Albert St, Ottawa



9:00 AM – 12:30 PM PST

Offices of Osler, Hoskin & Harcourt LLP
Bentall Four, 1055 Dunsmuir St, Vancouver



  1. What is the problem that the global minimum tax is trying to solve?
    1. How did we get here? (including context re: earlier OECD work)
    2. Divergence in optimal rates for different purposes of corporate taxation
    3. Alternatives?

  2. How does the global minimum tax solve that problem?
    1. Coordinated and prioritised ordering rules in imposing tax
    2. Collective base and tax credit rules

  3. The UTPR
    1. Collective crediting mechanism
    2. The UTPR and the Treaties / international law

  4. Tax incentives
    1. Why can’t all credits be treated as additional income?
    2. Why ‘monetizable’ is the right line ?
    3. What impact does the new line have on the provision of incentives?

  5. GILTI and the GloBE – thinking about two ‘global minimum taxes’
    1. Dealing with the reality of non-alignment – management of GILTI as a CFC tax
    2. Possibility of alignment after 2024? – managing a revised GILTI as a qualified IIR

  6. The future
    1. What does success look like?
      1. Phase 1 – Sufficient adoption to achieve coverage
      2. Phase 2 – Imposing the minimum tax outside the IIR/UTPR
      3. Phase 3 – Reduction in avoidance activities
      4. Institutional structure
    2. What’s next?

Heydon Wardell-Burrus is a Senior Advisor at the Centre for Tax Policy and Administration at the OECD. Prior to joining the OECD, he was a researcher at the Oxford Centre for Business Taxation and a visiting scholar at Columbia Law School. Heydon was previously an Australian delegate to the OECD’s Working Party 11 and a Senior Associate at Allens Linklaters in Sydney focusing on large international tax matters. Heydon teaches international tax law at the Universities of Oxford and Melbourne and is completing his DPhil at Oxford in International Taxation.

9:00 am | Registration and light breakfast

9:30 am | Lectureship

12:30 pm | Adjournment


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