Summary of the Proceedings of an Invitational Seminar on Tax Treaties in the 21st Century

Canadian Tax Journal, January, 2002 by Brian J. Arnold, Jacques Sasseville, and Eric Zolt*

Introduction

The importance of tax treaties has increased significantly in recent years as a consequence of the globalization of the economy and the liberalization of cross-border trade and investment. The number of bilateral tax treaties currently in force exceeds 2,500. The model tax convention of the Organisation for Economic Co-operation and Development (OECD),[1] on which virtually all bilateral treaties are based, is now revised on a regular basis. The United Nations (UN) model convention[2] was revised in 2001. Despite their importance and their phenomenal growth in recent years, tax treaties are often criticized for their fundamental deficiencies. Therefore, the time seems appropriate for a fundamental review of the role of tax treaties in facilitating international...

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