摘要：We have noted in other issues of the journal our hope that the timely publication
of commentary on important Canadian tax issues will both provoke and facilitate
informed discussion, to enlighten how these issues are understood and possibly,
as well, to contribute to how they mature as tax policy and ultimately tax legislation.
In this issue, we include several contributions sparked by the March 19, 2007 federal
budget’s review of how international income earned indirectly by Canadian taxpayers
should be taxed. The budget and the discussion that immediately ensued, culminating
in additional announcements by the minister of finance in May 2007, and in now
impending legislation, notably section 18.2 and certain changes to the foreign affiliate
rules to expand the reach of the exempt surplus regime, foreshadow a fundamental
re-examination of important structural elements of the Canadian tax system bearing
on the measurement and taxation of international income. This development, interestingly,
does not raise new considerations (as the history of Canadian income
taxation shows). As well, Canada is not the only country that is trying to come to
grips with how the globalization of international business impinges on the adequacy
and effectiveness of a tax system, in the context of larger business, commercial, and
trading arrangements with broader economic effects.
