In the consultation paper, the advisory panel set out the following possible approaches to treaty shopping (paragraph 3.23):

As noted above, certain treaty benefits are afforded to "beneficial owners" who are resident in a treaty country. The CRA has challenged some structures on the basis that the person resident in the treaty country who is

EVER since he has become the 47th President of the United States, Mr. Donald Trump has turned the world topsy-turvy. In his world view, the international order whether in the sphere of the balance of power between states or running of international institutions, or in the sphere of international trade or for that matter