The source concept of income is difficult to pin down in Canadian income tax law. It is elusive and defies simple explication. Nowhere is this more true than in the context of gambling winnings. In this essay, the tax treatment of poker and other gambling winnings is used as a window into how...

Until now the legal and regulatory measures that have been taken in the United States and Canada to combat excessive executive compensation have been largely ineffectual. The one possible exception is the tax deductibility cap of ý162(m) of the US Internal Revenue Code, which was introduced in...

Despite its complexity and the harsh reception the Canadian Goods and Services Tax (GST/HST) was greeted with at its inception in the early 1990s, the story emerging from Canada's value-added tax (VAT) experience is mostly a happy one. Indeed, a majority of the provinces will soon have replaced...

In the constitutional moment known to Canadians as Confederation, in 1867 the UK Parliament passed the British North America Act, 1867 (now known as the Constitution Act, 1867), thereby creating the Dominion of Canada. From the time of Confederation, there have been, broadly speaking, two sets...

In Canadian income tax law, winnings from gambling are taxable when they constitute “income from a source.” What is not clear is the basis for determining when, where, and how winnings from gambling activities can amount to “income from a source.” In light of recent decisions of the Tax...

Interestingly, Canada has had relatively little recent experience with anything like the heated concerns expressed in American and EU tax policy circles regarding excessive compliance costs of corporate income taxes. The lack of debate regarding compliance costs cannot be attributed to a...