My blogs in 2026 have examined cases where tax authorities’ requests for information, either for their own investigations or in connection with exchanges with other authorities, have been contested…
The recent decision of the Federal Court of Canada in Canada (National Revenue) v. Shopify Inc. (2025 FC 968) is a rare decision on the Joint Council of Europe/OECD Convention on Mutual…
Increased focus on taxation of cross-border situations involving both individuals and companies is one of the key features of the post-BEPS international tax environment. One central aspect of this…
A thought-provoking and insightful series of papers on taxpayer rights have just been published in the latest edition of The Tax Lawyer,[1] published by the American Bar Association Section of…
