Jinyan Li (Osgoode) & Angelo Nikolakakis (EY Law LLP), Offshore Tax Havens: An Intriguing Problem for Canadian Tax Law, 2025 Tax Notes Today, Int’l 231-17 (Dec. 4, 2025)

The use of offshore tax havens by Canadians and multinational enterprises is an intriguing problem for Canadian tax law. This submission explains why that is the case and recommends a systematic review of the existing law and specific reform ideas…

Taxpayers can use tax haven entities (e.g., corporations, trusts or investment funds) to evade, avoid or defer Canadian income taxes. That is a problem from a fiscal and fairness perspective. The problem should be addressed effectively by tax law. However, the fact that the problem has persisted despite the proliferation of anti-avoidance rules suggests that the solution is not as simple as some might have wished. In this submission, we explain why and how the problem is intriguing for Canadian tax law and what Canada can do to better address it….