Beneficial Ownership in International Taxation – Origins, Evolution and Future Role

*Taking place in-person in Toronto, streaming live simultaneously from offices in Vancouver, Calgary, Ottawa and Montreal.

Beneficial ownership is a fundamental concept in determining a taxpayer’s entitlement to tax treaty benefits. Longstanding jurisprudence in Canada has recently been reconsidered by the Federal Court of Appeal in Canada. Speakers Blazej Kuzniacki and Robert Raizenne will discuss the elaboration and historical development of the beneficial ownership concept and the role the concept currently plays in international taxation. The scope of beneficial ownership as defined in sometimes conflicting international jurisprudence and the parameters set by the OECD will be discussed. The speakers will also comment on its future role in a changing international taxation landscape, addressing continuing uncertainty in this area.

Guest Lecturers:

Błażej Kuźniacki, Global Tax Policy & International Tax Services at PwC Netherlands | Professor of Law at Lazarski University | Senior Research Affiliate at Singapore Management University

Robert Raizenne, Tax Partner, adjunct professor of tax law at McGill University’s Faculty of Law and the Faculty of Law at the University of Toronto, Osler, Hoskin & Harcourt LLP