Pub Date : 2021-11-01DOI: 10.32721/ctj.2021.69.3.pf.ledressay
André Le Dressay
The debate with respect to the recognition of Indigenous rights, title, and jurisdiction has largely been won. It has now moved to how best to implement those rights, title, and inherent jurisdictions. For Indigenous taxation jurisdiction, implementation must address challenges related to taxpayer representation, concurrent jurisdiction, service agreements with other governments, administrative capacity, financial management, and access to public debt capital at competitive rates. In this article, the author argues that the First Nations Fiscal Management Act (FMA) has been successful in overcoming these challenges. The FMA has protected and expanded Indigenous tax jurisdiction through standards and institutional support. As a result, it represents an effective path for interested Indigenous governments "to exercise [their] inherently governmental power of taxation" affirmed by the Supreme Court of Canada in Matsqui Indian Band, and to expand their use of that power.
{"title":"Policy Forum: In Defence of the First Nations Fiscal Management Act","authors":"André Le Dressay","doi":"10.32721/ctj.2021.69.3.pf.ledressay","DOIUrl":"https://doi.org/10.32721/ctj.2021.69.3.pf.ledressay","url":null,"abstract":"The debate with respect to the recognition of Indigenous rights, title, and jurisdiction has largely been won. It has now moved to how best to implement those rights, title, and inherent jurisdictions. For Indigenous taxation jurisdiction, implementation must address challenges related to taxpayer representation, concurrent jurisdiction, service agreements with other governments, administrative capacity, financial management, and access to public debt capital at competitive rates. In this article, the author argues that the First Nations Fiscal Management Act (FMA) has been successful in overcoming these challenges. The FMA has protected and expanded Indigenous tax jurisdiction through standards and institutional support. As a result, it represents an effective path for interested Indigenous governments \"to exercise [their] inherently governmental power of taxation\" affirmed by the Supreme Court of Canada in Matsqui Indian Band, and to expand their use of that power.","PeriodicalId":375948,"journal":{"name":"Canadian Tax Journal/Revue fiscale canadienne","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2021-11-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"114810712","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2021-11-01DOI: 10.32721/ctj.2021.69.3.sturm
Susan P. Sturm
This study examines the complexity of Canada's corporate income tax system from the perspective of multinational corporations and compares it with the complexity of the US system, also taking into account measures of complexity for 19 other member countries of the Organisation for Economic Co-operation and Development (OECD). The author finds that with regard to the Canadian tax code, the most complex laws are those on corporate reorganization, transfer pricing, and controlled foreign corporations, and with regard to the Canadian tax framework, the most complex areas are tax audits, tax-law enactment, and tax guidance. In comparison with other OECD countries, Canada is remarkably similar to the United States. Both countries have a medium level of overall complexity, and both have a more complex tax code but a less complex tax framework than other countries. However, a closer examination of the Canadian and US tax codes and tax frameworks reveals some significant differences in complexity levels, particularly in respect of certain tax laws.
{"title":"Income Tax Complexity Faced by Multinational Corporations: A Comparative Study of Canada, the United States, and Other Selected OECD Countries","authors":"Susan P. Sturm","doi":"10.32721/ctj.2021.69.3.sturm","DOIUrl":"https://doi.org/10.32721/ctj.2021.69.3.sturm","url":null,"abstract":"This study examines the complexity of Canada's corporate income tax system from the perspective of multinational corporations and compares it with the complexity of the US system, also taking into account measures of complexity for 19 other member countries of the Organisation for Economic Co-operation and Development (OECD). The author finds that with regard to the Canadian tax code, the most complex laws are those on corporate reorganization, transfer pricing, and controlled foreign corporations, and with regard to the Canadian tax framework, the most complex areas are tax audits, tax-law enactment, and tax guidance. In comparison with other OECD countries, Canada is remarkably similar to the United States. Both countries have a medium level of overall complexity, and both have a more complex tax code but a less complex tax framework than other countries. However, a closer examination of the Canadian and US tax codes and tax frameworks reveals some significant differences in complexity levels, particularly in respect of certain tax laws.","PeriodicalId":375948,"journal":{"name":"Canadian Tax Journal/Revue fiscale canadienne","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2021-11-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"131478134","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2021-11-01DOI: 10.32721/ctj.2021.69.3.ctp
Andrew Barton, Vinu Subramaniam, Paola Marino
The impact of the COVID-19 pandemic has varied significantly across market sectors and companies, and the disruptions generated by the pandemic have had major implications for the transfer-pricing practices of many multinationals. The COVID-19 crisis has challenged the efficiency of traditional benchmarking of profit margins and markups on the basis of the profitability of comparable companies. In this article, we provide a framework for addressing two key questions: (1) how to ensure that the data used for setting or testing transfer-pricing results are appropriate in terms of comparability and that they adequately reflect economic reality for the tested party; and (2) what adjustments need to be made if the tested party's results fall below the arm's-length range. Given the extraordinary circumstances, we cannot rely on a simple analysis of historical data to adjust for the impact faced by businesses as a result of COVID-19. For example, in situations where the taxpayer's results have been affected by the COVID-19 pandemic to a greater extent than the results of comparable companies, the approaches outlined in this article will provide the taxpayer with an estimated arm's-length range of profitability for the comparable companies that is calibrated to the impact of the pandemic on the tested party's results. These approaches are aligned with the transfer-pricing guidance for COVID-19 adjustments issued by the Organisation for Economic Co-operation and Development in December 2020.
{"title":"Corporate Tax Planning: Impact of COVID-19 and Transfer Pricing: Approaches for Comparability Adjustments","authors":"Andrew Barton, Vinu Subramaniam, Paola Marino","doi":"10.32721/ctj.2021.69.3.ctp","DOIUrl":"https://doi.org/10.32721/ctj.2021.69.3.ctp","url":null,"abstract":"The impact of the COVID-19 pandemic has varied significantly across market sectors and companies, and the disruptions generated by the pandemic have had major implications for the transfer-pricing practices of many multinationals. The COVID-19 crisis has challenged the efficiency of traditional benchmarking of profit margins and markups on the basis of the profitability of comparable companies. In this article, we provide a framework for addressing two key questions: (1) how to ensure that the data used for setting or testing transfer-pricing results are appropriate in terms of comparability and that they adequately reflect economic reality for the tested party; and (2) what adjustments need to be made if the tested party's results fall below the arm's-length range. Given the extraordinary circumstances, we cannot rely on a simple analysis of historical data to adjust for the impact faced by businesses as a result of COVID-19. For example, in situations where the taxpayer's results have been affected by the COVID-19 pandemic to a greater extent than the results of comparable companies, the approaches outlined in this article will provide the taxpayer with an estimated arm's-length range of profitability for the comparable companies that is calibrated to the impact of the pandemic on the tested party's results. These approaches are aligned with the transfer-pricing guidance for COVID-19 adjustments issued by the Organisation for Economic Co-operation and Development in December 2020.","PeriodicalId":375948,"journal":{"name":"Canadian Tax Journal/Revue fiscale canadienne","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2021-11-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"115686981","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2021-11-01DOI: 10.32721/ctj.2021.69.3.pf.icton
Mike Icton, Devan Mescall
Urban reserves offer a unique economic development tool for First Nation governments by providing access to markets and infrastructure unavailable on most reserve lands in Canada. Asimakiniseekan Askiy is Canada's first urban reserve established on land previously owned by a city. The urban reserve was established in Saskatoon by the Muskeg Lake Cree Nation in 1988. Asimakiniseekan Askiy provides an example of the economic potential of urban reserves for First Nations and their members, as well as municipal governments and their citizens. The urban reserve is currently home to 60 First Nation and non-First Nation businesses and their 700 employees. In 2020, the urban reserve contributed $465,662 to the city of Saskatoon in service fee payments. However, before this economic potential could be realized, property taxation presented a sizable barrier in the path of taking Asimakiniseekan Askiy from an innovative idea to a successful reality. Establishing an urban reserve has significant property tax implications, since the process requires the transfer of property from the taxing authority of a municipal jurisdiction to the tax jurisdiction of a First Nation government. Agreements providing for the transfer of tax authority also include negotiations relating to the continued provision of services to the urban reserve by the municipality. This article first provides a summary of the statutory environment surrounding the formation and taxation of an urban reserve. A case study of the establishment and 33 years of operation of Asimakiniseekan Askiy is then provided, to illustrate the property tax implications and municipal service agreement process necessary for Canadian communities to achieve the economic benefits of urban reserves. The authors identify property tax challenges inherent in the establishment of an urban reserve and offer recommendations to improve access to urban reserves as an innovative economic development tool.
{"title":"Policy Forum: Establishing an Urban Reserve—Property Tax Challenges and Opportunities","authors":"Mike Icton, Devan Mescall","doi":"10.32721/ctj.2021.69.3.pf.icton","DOIUrl":"https://doi.org/10.32721/ctj.2021.69.3.pf.icton","url":null,"abstract":"Urban reserves offer a unique economic development tool for First Nation governments by providing access to markets and infrastructure unavailable on most reserve lands in Canada. Asimakiniseekan Askiy is Canada's first urban reserve established on land previously owned by a city. The urban reserve was established in Saskatoon by the Muskeg Lake Cree Nation in 1988. Asimakiniseekan Askiy provides an example of the economic potential of urban reserves for First Nations and their members, as well as municipal governments and their citizens. The urban reserve is currently home to 60 First Nation and non-First Nation businesses and their 700 employees. In 2020, the urban reserve contributed $465,662 to the city of Saskatoon in service fee payments. However, before this economic potential could be realized, property taxation presented a sizable barrier in the path of taking Asimakiniseekan Askiy from an innovative idea to a successful reality. Establishing an urban reserve has significant property tax implications, since the process requires the transfer of property from the taxing authority of a municipal jurisdiction to the tax jurisdiction of a First Nation government. Agreements providing for the transfer of tax authority also include negotiations relating to the continued provision of services to the urban reserve by the municipality. This article first provides a summary of the statutory environment surrounding the formation and taxation of an urban reserve. A case study of the establishment and 33 years of operation of Asimakiniseekan Askiy is then provided, to illustrate the property tax implications and municipal service agreement process necessary for Canadian communities to achieve the economic benefits of urban reserves. The authors identify property tax challenges inherent in the establishment of an urban reserve and offer recommendations to improve access to urban reserves as an innovative economic development tool.","PeriodicalId":375948,"journal":{"name":"Canadian Tax Journal/Revue fiscale canadienne","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2021-11-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"125891088","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2021-11-01DOI: 10.32721/ctj.2021.69.3.pf.mccue
Kate McCue, Billy McCue
In 2018, the Chippewas of Georgina Island First Nation (GIFN) implemented a First Nation property tax system under the First Nations Fiscal Management Act (FMA)—one of the earliest First Nations in Ontario to do so. Implementation of a property tax system gave GIFN an opportunity to improve funding for and expand local services, and provide a more equitable sharing of local service costs between cottagers leasing First Nation land and the First Nation. Key challenges encountered when implementing the property tax system were building consensus around the need for a tax system, building an appropriate administrative infrastructure, carrying out property assessments, and professionals lacking knowledge of First Nation property tax. These challenges, however, presented opportunities to create a knowledge base around property taxation within GIFN, among cottage leaseholders, and in the wider community. Key lessons learned were (1) start as soon as possible; (2) First Nations Tax Commission support and standards are important; (3) staff training is important; (4) communicate early and often; (5) hold open houses; (6) local services are more than garbage collection; (7) property taxes do not harm lease rates or cottage sales; (8) educate lawyers, real estate agents, and other professionals; (9) startup costs were significant; (10) coordinate laws and standards with provincial variations; (11) modernize systems; and (12) utilize other parts of the FMA.
{"title":"Policy Forum: Implementing the Chippewas of Georgina Island First Nation Property Tax System—Opportunities, Challenges, and Lessons Learned","authors":"Kate McCue, Billy McCue","doi":"10.32721/ctj.2021.69.3.pf.mccue","DOIUrl":"https://doi.org/10.32721/ctj.2021.69.3.pf.mccue","url":null,"abstract":"In 2018, the Chippewas of Georgina Island First Nation (GIFN) implemented a First Nation property tax system under the First Nations Fiscal Management Act (FMA)—one of the earliest First Nations in Ontario to do so. Implementation of a property tax system gave GIFN an opportunity to improve funding for and expand local services, and provide a more equitable sharing of local service costs between cottagers leasing First Nation land and the First Nation. Key challenges encountered when implementing the property tax system were building consensus around the need for a tax system, building an appropriate administrative infrastructure, carrying out property assessments, and professionals lacking knowledge of First Nation property tax. These challenges, however, presented opportunities to create a knowledge base around property taxation within GIFN, among cottage leaseholders, and in the wider community. Key lessons learned were (1) start as soon as possible; (2) First Nations Tax Commission support and standards are important; (3) staff training is important; (4) communicate early and often; (5) hold open houses; (6) local services are more than garbage collection; (7) property taxes do not harm lease rates or cottage sales; (8) educate lawyers, real estate agents, and other professionals; (9) startup costs were significant; (10) coordinate laws and standards with provincial variations; (11) modernize systems; and (12) utilize other parts of the FMA.","PeriodicalId":375948,"journal":{"name":"Canadian Tax Journal/Revue fiscale canadienne","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2021-11-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"133516473","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2021-08-01DOI: 10.32721/ctj.2021.69.2.ustd
Michael J. Miller
In the United States, statutes and treaties are on an equal footing. Thus, in the event of a conflict between a statute and a treaty, the treaty does not automatically take precedence over the statute. Moreover, the US courts go to great lengths to avoid finding the existence of any conflict. This article discusses a recent case in which the Tax Court held, among other things, that a punitive deduction-disallowance rule applicable solely to non-US persons did not conflict with the non-discrimination article of the income tax treaty in effect between the United States and Canada.
{"title":"Selected US Tax Developments: Adams Challenge (UK) Limited: When Does a Treaty Provision Conflict with the Code?","authors":"Michael J. Miller","doi":"10.32721/ctj.2021.69.2.ustd","DOIUrl":"https://doi.org/10.32721/ctj.2021.69.2.ustd","url":null,"abstract":"In the United States, statutes and treaties are on an equal footing. Thus, in the event of a conflict between a statute and a treaty, the treaty does not automatically take precedence over the statute. Moreover, the US courts go to great lengths to avoid finding the existence of any conflict. This article discusses a recent case in which the Tax Court held, among other things, that a punitive deduction-disallowance rule applicable solely to non-US persons did not conflict with the non-discrimination article of the income tax treaty in effect between the United States and Canada.","PeriodicalId":375948,"journal":{"name":"Canadian Tax Journal/Revue fiscale canadienne","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2021-08-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"115074488","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2021-08-01DOI: 10.32721/ctj.2021.69.2.pf.jason
Guy Jason, Shivani Joshi
Embracing remote work, either fully or partially, allows employers to offer the flexibility that many employees are seeking and also to benefit from various cost savings. As organizations embark on this journey, there are many tax and payroll considerations that should be reviewed up front so that risks relating to non-compliance can be mitigated. What are these corporate tax and payroll considerations? Can a formal policy help to mitigate compliance risks? What are other considerations besides tax and payroll? Should government policy support this workforce shift? This article summarizes the various considerations in developing an organizational remote work policy and concludes that, as is the case for any other business strategy, remote work arrangements have their benefits provided that the associated complexity and costs can be effectively managed.
{"title":"Policy Forum: Future Workforce Models—Enabling the Shift","authors":"Guy Jason, Shivani Joshi","doi":"10.32721/ctj.2021.69.2.pf.jason","DOIUrl":"https://doi.org/10.32721/ctj.2021.69.2.pf.jason","url":null,"abstract":"Embracing remote work, either fully or partially, allows employers to offer the flexibility that many employees are seeking and also to benefit from various cost savings. As organizations embark on this journey, there are many tax and payroll considerations that should be reviewed up front so that risks relating to non-compliance can be mitigated. What are these corporate tax and payroll considerations? Can a formal policy help to mitigate compliance risks? What are other considerations besides tax and payroll? Should government policy support this workforce shift? This article summarizes the various considerations in developing an organizational remote work policy and concludes that, as is the case for any other business strategy, remote work arrangements have their benefits provided that the associated complexity and costs can be effectively managed.","PeriodicalId":375948,"journal":{"name":"Canadian Tax Journal/Revue fiscale canadienne","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2021-08-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"131397274","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2021-08-01DOI: 10.32721/ctj.2021.69.2.mescall
Devan Mescall, Paul Nielsen
Using data from the annual reports of over 100,000 subsidiaries of multinational enterprises (MNEs) from 55 countries between 2003 and 2012, the authors of this article investigate the impact of exchange-of-information agreements ("EOI agreements") on tax-motivated income shifting. Transparency created by the signing of EOI agreements is expected to reduce the tax-motivated shifting of income by multinational corporations. Whether such agreements affect the income-shifting behaviour of multinational corporations is an unanswered question. The authors find evidence that, on average, EOI agreements do have an impact on tax-motivated income shifting. Additionally, they find that more advanced, modern EOI agreements are associated with a larger decrease in tax-motivated income shifting compared to the impact of early EOI agreements. This evidence challenges the prevalent assumption in empirical studies that EOI agreements are homogeneous. Supplemental analyses suggest that factors that affect the information asymmetry between MNEs and tax authorities, such as corporations with high levels of intangibles and tax authorities with strong transfer-pricing rules and enforcement, can diminish or enhance the effectiveness of EOI agreements in moderating tax-motivated income shifting. The evidence provided by this study shows that consideration of the tax authorities' information environment and the substance of an EOI agreement is essential when assessing the impact of such an agreement on the tax behaviour of sophisticated taxpayers such as multinational corporations.
{"title":"Corporate Income Shifting in an Era of Tax Multilateralism: The Impact of Exchange-of-Information Agreements","authors":"Devan Mescall, Paul Nielsen","doi":"10.32721/ctj.2021.69.2.mescall","DOIUrl":"https://doi.org/10.32721/ctj.2021.69.2.mescall","url":null,"abstract":"Using data from the annual reports of over 100,000 subsidiaries of multinational enterprises (MNEs) from 55 countries between 2003 and 2012, the authors of this article investigate the impact of exchange-of-information agreements (\"EOI agreements\") on tax-motivated income shifting. Transparency created by the signing of EOI agreements is expected to reduce the tax-motivated shifting of income by multinational corporations. Whether such agreements affect the income-shifting behaviour of multinational corporations is an unanswered question. The authors find evidence that, on average, EOI agreements do have an impact on tax-motivated income shifting. Additionally, they find that more advanced, modern EOI agreements are associated with a larger decrease in tax-motivated income shifting compared to the impact of early EOI agreements. This evidence challenges the prevalent assumption in empirical studies that EOI agreements are homogeneous. Supplemental analyses suggest that factors that affect the information asymmetry between MNEs and tax authorities, such as corporations with high levels of intangibles and tax authorities with strong transfer-pricing rules and enforcement, can diminish or enhance the effectiveness of EOI agreements in moderating tax-motivated income shifting. The evidence provided by this study shows that consideration of the tax authorities' information environment and the substance of an EOI agreement is essential when assessing the impact of such an agreement on the tax behaviour of sophisticated taxpayers such as multinational corporations.","PeriodicalId":375948,"journal":{"name":"Canadian Tax Journal/Revue fiscale canadienne","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2021-08-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"130832196","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2021-08-01DOI: 10.32721/ctj.2021.69.2.pfp
Ana-Luiza Georgescu
Cet article traite des principales catégories de programmes de rémunération aux fins de l'impôt et décrit quelques-unes des conséquences fiscales que peuvent avoir certains changements apportés à ces programmes de rémunération, ainsi que des moyens d'atténuer ces effets fiscaux. Il examine également les modifications législatives proposées être apportées dans le domaine des options d'achat d'actions, et propose des mesures que les entreprises devraient prendre en prévision de ces modifications. En outre, dans le contexte de la pandémie de COVID-19, cet article aborde les aspects clés du [laquo] travail de n'importe où [raquo] relativement à certains programmes de rémunération, ainsi que l'effet éventuel et attendu des impératifs environnementaux, sociaux et de gouvernance des sociétés dans la conception et la détermination de la rémunération des dirigeants.
{"title":"Planification fiscale personnelle : Les enjeux actuels de la rémunération","authors":"Ana-Luiza Georgescu","doi":"10.32721/ctj.2021.69.2.pfp","DOIUrl":"https://doi.org/10.32721/ctj.2021.69.2.pfp","url":null,"abstract":"Cet article traite des principales catégories de programmes de rémunération aux fins de l'impôt et décrit quelques-unes des conséquences fiscales que peuvent avoir certains changements apportés à ces programmes de rémunération, ainsi que des moyens d'atténuer ces effets fiscaux. Il examine également les modifications législatives proposées être apportées dans le domaine des options d'achat d'actions, et propose des mesures que les entreprises devraient prendre en prévision de ces modifications. En outre, dans le contexte de la pandémie de COVID-19, cet article aborde les aspects clés du [laquo] travail de n'importe où [raquo] relativement à certains programmes de rémunération, ainsi que l'effet éventuel et attendu des impératifs environnementaux, sociaux et de gouvernance des sociétés dans la conception et la détermination de la rémunération des dirigeants.","PeriodicalId":375948,"journal":{"name":"Canadian Tax Journal/Revue fiscale canadienne","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2021-08-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"113956771","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
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