Canadian Income Taxation of Sovereign Wealth Funds

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This thesis is a comparative analysis of the Canadian income taxation of sovereign wealth funds (SWFs). Because SWFs are owned and controlled by foreign governments, they are subject to different rules than private foreign investors, notably tax rules. The taxation of SWFs in Canada is determined by the interaction of domestic tax rules, bilateral tax treaties, and the law of state immunity. In certain cases, SWFs may be immune from taxation. The thesis examines the Canadian tax law and policy applicable to SWFs and compares Canadian practice to that of three other jurisdictions (Australia, Germany and the United States). In particular, it argues that the existing rules lack certainty and transparency and recommends legislative change to address these shortcomings.  
sovereign immunity, sovereign weatlh funds, state immunity, taxation, income tax
Ryer, Andrea M. (2018). Canadian Income Taxation of Sovereign Wealth Funds (Master's thesis, University of Calgary, Calgary, Canada). Retrieved from doi:10.11575/PRISM/13058