Jacques SassevilleFormerly Inter-regional Adviser at the United Nations (DESA-FSDO) (2017-2020), Head of the Tax Treaty Unit at the Centre for Tax Policy and Administration of the OECD (1995-2017) and principal administrator and subsequently deputy head of the OECD Fiscal Affairs Division (1990-1993). He has also worked with the Federal Government of Canada as counsel in the Tax Counsel Division (Department of Justice ) and as head of Tax Treaties (Department of Finance), as professor in the Department of Accounting Sciences at the University of Quebec at Montreal, as researcher and lecturer at the law faculty of the University of Montreal and as a tax lawyer in a Canadian law firm. He has written and lectured extensively on Canadian and international tax issues and was a member of the Permanent Scientific Committee of the International Fiscal Association from 2002 to 2017.
Preventing Treaty Abuse
This course will deal with strategies that are used to circumvent the provisions of tax treaties (or the provisions of domestic law through the use of tax treaties), and will examine the various tools that are used to address these strategies. Using examples derived from case law, the main types of treaty abuses will be examined. The various interpretative approaches and the specific and general anti-abuse rules found in tax treaties that may serve to prevent treaty abuse, including limitation-on-benefits and principal purposes rules, will also be presented and analyzed with references to the report on BEPS Action 6 and the relevant provisions of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting. The course will also address the specific and general rules and judicial doctrines found in domestic law and examine their interaction with tax treaties.
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