Treaty shopping in Canada : the door is (still) open

The Canadian courts have recently considered the subject of treaty shopping, and the decisions so far have been favourable to taxpayers. This article reviews Canada's current position on treaty shopping and looks at where Canada is headed on this issue. The article examines these two topics in terms of treaty residence, beneficial ownership, limitation on benefits and domestic anti-avoidance rules. The article also discusses whether there is an inherent anti-abuse rule in tax treaties.