There are numerous large Canadian multi-national corporations (e.g., Petro Canad

There are numerous large Canadian multi-national corporations (e.g., Petro Canada, Loblaws, Barrick Gold, Guildan, Bell Canada, BMO) that rely on the use of foreign subsidiaries to transfer profits from Canada to lower tax jurisdictions. Some estimate that the capital outflow from Canada to these offshore tax havens is somewhere between $10-$15 billion annually. While these practices are considered completely legal, they may or not be considered ethical. Based on the objective of “tax fairness” by the Canadian tax system, do you agree or disagree that the use of off-shore tax havens by multi-national embodies tax fairness? Does the legal use of tax havens enable or hinder the global competiveness of the Canadian economy? Who are the stakeholders that benefit from the deferral or avoidance of tax on profits earned by multi-nationals doing business in Canada? A complete discussion will offer perspectives from both sides of the argument, and evidence to support a conclusion. In your analysis, you may wish to consider the rules of GAAR from chapter 13. Does your argument change (or not) if you assume that CCPCs are unable to generate foreign income, and therefore make-use of the corporate structures that facilitate off-shore tax havens. Should tax fairness be a question of relative comparison among individuals, small business, and large business? 

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