Publications
Vern Krishna CM, KC, LSM, FCPA
2023
- 07-11-23: GAAR and Tax Treaties
- 06-29-23: GAAR Clips Westminster’s Wings
- 06-23-23: The Westminster Principle
- 06-09-23: Treaty Shopping and Tax Avoidance
- 05-05-23: The Revenue Rule in Tax Law
- 01-07-23: Speculators Get Relief from Crypto Losses
2022
2021
- 12-27-21: A Tax Loophole Benefits the Other Guy. If it Benefits You, it is “Tax Reform”
- 10-14-21: The Ancient Art of Taxation
- 06-15-21: Payment of Taxes
- 04-12-21: File Your Tax Return on Time and Stay Safe
- 02-10-21: Stock Traders Beware of Tax Traps: The Taxman Cometh
- 01-19-21: A Brief History on the Unpleasant Subject of Taxes
2020
- 05-20-20: “Bottom Line Profits”: “It Ain’t Necessarily So”
- 04-23-20: Time Is Money: Part 2
- 04-07-20: Time Value of Money
- 03-09-20: Accounting Principles: Part I
- 01-02-20: The Long History of Taxation
2019
- 12-16-19: Brief Overview of Tax History
- 12-03-19: Tax Reform, Less Talk and More Action, Please
- 10-28-19: The Nature of Taxes
- 09-05-19: Whose Income is it?
- 04-08-19: Bribery and Corruption in International Business
- 04-01-19: Fines and Penalties
- 02-25-19: Bribery and the Rule of Law
2018
- 10-01-18: The Three Steps of GAAR – Taxnet Pro: Tax Disputes & Resolution Centre
- 04-27-18: Tax Views: Taxation of cryptocurrency transactions – The Lawyer’s Daily
- 03-29-18: International Taxation of Business Profits – Canadian Current Tax
- 03-21-18: Bitcoin Taxation Basics – Financial Post
- 03-12-18: The Fiscal Landscape: Part 2 – Tax Policy – Canadian Current Tax
- 03-05-18: Tax Views: Federal budget changes rules for investment income of private corporations – The Lawyer’s Daily
- 03-02-18: This year’s big taxation question: How to file cryptocurrency use? – Financial Post
- 03-02-18: Tax Views: Taxation of multinational enterprises – The Lawyer’s Daily
- 02-01-18: The Fiscal Landscape: Part 1 – Canadian Current Tax
- 01-22-18: Tax Views: The OECD’s reaction to international tax planning – The Lawyer’s Daily
- 01-17-18: Year end tax planning for business & CRA gets failing grade on its public duties – Canadian Current Tax
- 01-10-18: Tax Views: Complex, uncertain split income rules not a good start to 2018 – The Lawyer’s Daily
2017
- 12-20-17: Taxpayers need a Bill of Rights – National Post
- 12-18-17: Tax Views: Year-end tax planning for business – The Lawyer’s Daily
- 11-17-17: Tax Views: Light shone on offshore trusts should be a red flag to lawyers and accountants – The Lawyer’s Daily
- 11-13-17: Why are tax haven loopholes so hard to close? – CTV
- 10-23-17: How Fair is Progressive Taxation? – The Lawyer’s Daily
- 09-18-17: Tax Views: Appealing tax assessments a long and expensive journey – The Lawyer’s Daily
- 09-13-17: Employee Versus Independent Contractor? – Canadian Current Tax
- 08-02-17: What is the Difference between an Uber Driver and a Lap Dancer? – Taxnet Pro™
- 06-13-17: Shareholder Liability for Corporate Taxes – Canadian Current Tax
- 06-06-17: Net Worth Assessments – Taxnet Pro™
- 03-31-17: Taxpayer Bill of Rights won’t speed up dispute process – The Lawyers Weekly
- 03-19-17: CRA Falls Down on its Public Duties – Taxnet Pro™
- 03-19-17: Tax Actions Beget Tax Reactions – Taxnet Pro™
- 03-15-17: Handle owner-manager compensation with care – National Post
- 02-28-17: Shareholder-Manager Compensation – Taxnet Pro™
- 01-19-17: Taxpayers must stand and wait to resolve their appeals
2016
- 12-28-16: Use and abuse of professional corporations
- 12-23-16: Incorporating firm can bring tax relief
- 12-21-16: Vern Krishna: Auditor General’s report shows Taxpayer Bill of Rights is merely feel-good PR – Financial Post
- 11-14-16: Government Tightens Rules for Principal Residences – Taxnet Pro™
- 11-14-16: Tax Deferral for Professional Corporations – Taxnet Pro™
- 10-30-16: Deduction of Expenses for Tax Purposes, Canadian Current Tax
- 09-30-16: Dispute Resolution in Tax Law, Canadian Current Tax
- 09-21-16: Bureaucrats and Taxing Powers – Taxnet Pro™
- 09-13-16: Vern Krishna: The big difference between ‘statutory’ and ‘effective’ tax rates
- 08-03-16: Pay the tax, then fight the battle
- 07-06-16: Constraints on Legal Privilege – Taxnet Pro™
- 07-05-16: Vern Krishna: Supreme Court protects professional secrecy
- 05-12-16: Taxable Benefits – Taxnet Pro™
- 04-05-16: Vern Krishna: Confidential doesn’t mean ‘privileged’ when it comes to advice from accountants
- 03-22-16: Tax collectors, beware wrath of the people
- 03-17-16: Vern Krishna: Tax law chips away at the tradition of solicitor-client privilege
- 01-06-16: Revamp Child-Care Tax Law
2015
- 12-02-15: A Subsidy by any Other Name – Taxnet Pro™
- 11-19-15: Corporate Transactions Require Experienced Eye
- 10-26-15: Canada Needs Taxpayer Bill of Rights – Taxnet Pro™
- 10-15-15: Vern Krishna: Canada needs a Charter of taxpayer rights
- 10-15-15: Professional corporation has tax advantage
- 10-15-15: Corporate tax incentives for small businesses
- 10-15-15: Coming to GRIPS with corporate dividends
- 10-13-15: Why leveraged donation tax schemes can get lawyers in trouble
- 09-08-15: The Regulation of Professional Corporations – Taxnet Pro™
- 08-17-15: The Meaning of Gift for Tax Purposes – Taxnet Pro™
- 07-15-15: Family Businesses Should Heed the Rules on Associated Corporations
- 06-11-15: Canada’s Complicated Tax Rules Fails to Recognize that a ‘Buck is a Buck’
- 04-15-15: The Source Doctrine is the Sauce for Confusion in Tax Law
- 04-13-15: Vern Krishna: Turning Canada into a goldmine for tax snoops – Financial Post
- 02-18-15: Vern Krishna: Corporate Barons Vote with Their Feet – Financial Post
2014
- 12-01-14: A model to guard against double taxation – The Bottom Line
- 11-24-14: Income Splitting is Fair – Taxnet Pro™
- 11-24-14: 2014 Year-end Tax Planning for Investors – Taxnet Pro™
- 11-03-14: Tax Sparing – Taxnet Pro™
- 11-01-14: Vern Krishna: The theory behind corporate taxes – The Bottom Line
- 10-01-14: Vern Krishna: U.S. ‘patch up’ doesn’t get to root cause of tax inversions – Financial Post
- 10-01-14: Tax tension within the Tim Hortons takeover – The Bottom Line
- 09-19-14: Tax Inversions – Taxnet Pro™
- 08-06-14: Canada should soften tax rules on property transfers between family members – Financial Post
- 06-24-14: Tax Erosion of Investment Returns – Taxnet Pro™
- 06-05-14: Return on Investment – Taxnet Pro™
- 06-05-14: The Fiduciary Duty of Investment Advisors – Taxnet Pro™
- 05-21-14: Understanding fiduciary relationships – Financial Post
- 03-26-14: U.S. steps up tax enforcement beyond – Financial Post
- 01-29-14: Tax court complicates use of double taxation treaties – Financial Post
- 01-08-14: Determining tax jurisdiction – Financial Post
2013
- 12-04-13: Vern Krishna debunks two tax myths – Financial Post
- 11-27-13: Tax planning is about timing your transactions wisely – Financial Post
- 11-13-13: Extending tax justice to the middle class – Financial Post
- 10-21-13: 2013 Year-End Tax Planning For Investors – Taxnet Pro™
- 09-26-13: Corporate Ethical Investing – Taxnet Pro™
- 09-25-13: CRA rules make it tough for employees to deduct legal fees – Financial Post
- 09-17-13: The Three Rs of Taxation – Taxnet Pro™
- 09-03-13: An easier way to police Canada’s senate residency requirement – Legal Post
- 08-21-13: Tax avoidance debate reaches back two centuries, Vern Krishna writes – Financial Post
- 07-23-13: There’s no such thing as ‘aggressive’ tax avoidance in law – Financial Post
- 05-29-13: Courts not keen to expand privilege to include accountants – Financial Post
- 04-30-13: The Extent of Privilege For Accountants – Taxnet Pro™
- 04-03-13: Foreign lawyers key to dealing with demand for legal services – Financial Post
- 04-03-13: Foreign Revenue Laws Need Enforcement – Taxnet Pro™
- 03-13-13: Accounting and the rule of law – Taxnet Pro™
- 02-13-13: The double whammy of bribes – Financial Post
- 01-31-13: How the Taxman Keeps Us From Falling Off The Cliff – Taxnet Pro™
- 01-31-13: Bribery of Foreign Officials – Taxnet Pro™
- 01-31-13: CRA Keeping Close Eye on Abusive Schemes – Taxnet Pro™
- 01-02-13: Beware of CRA’s formidable audit powers – Financial Post
2012
- 12-05-12: Be careful how you give to charity – Financial Post
- 11-28-12: Plain meaning and the purposive approach – Taxnet Pro™
- 11-07-12: Who pays how much tax? – Taxnet Pro™
- 11-01-12: Tax Revolutions – Taxnet Pro™
- 11-01-12: Offshore Trusts – Taxnet Pro™
- 10-19-12: Taxman still gouges, but at least not your eyes – Taxnet Pro™
- 10-05-12: Tax Appeals: General vs. Informal – Taxnet Pro™
- 10-31-12: Determining when a levy is really a tax – Financial Post
- 09-20-12: Parsing the new accounting landscape – Taxnet Pro™
- 09-20-12: Americans targeting dual citizens in tax probe – Taxnet Pro™
- 09-20-12: Timing is all in notices of objection – Taxnet Pro™
- 09-20-12: What CRA wants, CRA usually gets – Taxnet Pro™
- 08-29-12: Clock never stops in CRA disputes – Financial Post
- 08-01-12: Why we hate the tax collector – Financial Post
- 07-03-12: An unnecessary overreaching of U.S tax law into Canada_Financial Post
- 06-06-12: Offshore no longer safe for trusts – Financial Post
- 05-17-12: Feds know who is likely to cheat – Taxnet Pro™
- 05-02-12: Resident or not, timing is everything – Taxnet Pro™
- 04-25-12: Canadian taxing double jeopardy – Financial Post
- 03-28-12: Fraud isn’t likely to disappear – Financial Post
- 03-01-12: Beware, tax pros, the hanging sword – Taxnet Pro™
- 01-25-12: It’s time to open legal doors – Financial Post
2011
- 10-12-11: Hard to slip long arm of Uncle Sam – Financial Post
- 09-19-11: Time to Relax Rules Against Income Splitting – Taxnet Pro™
- 09-01-11: Statutes Can Delay Income Deductions – Taxnet Pro™
- 08-24-11: Canada has hundreds of tax havens, coast to coast – Financial Post
- 08-09-11: Tax Court takes things literally – Financial Post
- 07-13-11: Income splitting promise appears wobbly – Financial Post
- 06-30-11: Deck Stacked Against Middle Class People – Taxnet Pro™
- 05-25-11: The pluses and minuses of business in India – Financial Post
- 05-20-11: The Art of Corporate Share Valuation – Taxnet Pro™
- 05-01-11: Tax Rates Must Remain Competitive – Taxnet Pro™
- 04-28-11: Taxes and Politicians – Taxnet Pro™
- 04-19-11: Tax litigation beyond the reach of most people – Financial Post
- 04-15-11: The Difficulty with Substance Doctrine – Taxnet Pro™
- 03-30-11: High Legal Services Costs – Taxnet Pro™
- 03-15-11: The Tax Rate Debate – Financial Post
- 01-12-11: Britain Steps Up War on Bribery – Taxnet Pro™
2010
- 05-19-10: Wife Can Be Liable for Spouse’s Tax Bill – Taxnet Pro™
- 06-09-10: Helping poor countries by sparing taxes – Taxnet Pro™
- 08-01-10: Common Interest Privilege in Corporate Transactions – Taxnet Pro™
- 08-11-10: Lord Black Case Highlights U.S. Tax Law Issues – Taxnet Pro™
- 09-08-10: Taxpayers require Bill of Rights – Taxnet Pro™
- 10-13-10: Greek Protests Over Tax Hikes Might Work – Taxnet Pro™
- 10-27-10: Bank secrecy under scrutiny – Taxnet Pro™
- 12-22-10: Swiss Tax Refuge Vanishes – Taxnet Pro™
2009
- 01-01-09: The Constitutional Power to Tax – Canadian Current Tax
- 01-14-09: Scheme Sets Up Legal, Tax Mess – Taxnet Pro™
- 04-01-09: Line Between Planning and Tax Abuse Unclear – Taxnet Pro™
- 04-22-09: Swiss Tax Fight Highlights Evasion Issue; U. S. Crackdown on Tax Havens Meets Resistance – Taxnet Pro™
- 06-17-09: Beware of Tax Audits and Investigations – Taxnet Pro™
- 08-19-09: Say-on-Pay Movement Takes Root – Taxnet Pro™
- 10-07-09: U.S. Tax-Evasion Crackdown Could Affect Canadians – Taxnet Pro™
- 11-16-09: Using Beneficial Ownership to Prevent Treaty Shopping – Taxnet Pro™
- 12-02-09: Dealing With a Tax-Search Warrant – Taxnet Pro™