Michael N. Kandev, Matthew Peters, "Treaty Interpretation: The Concept of 'Beneficial Owner' in the Canadian Tax Treaty Theory and Practice", Canadian Tax Foundation, 2011 Conference Report, 26:1-60

In the course of reviewing the meaning of "beneficial owner" under the OECD model convention, Kandev and Peters stated (at p. 28):

The...

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Is "beneficial owner" a question of legal or economic substance? (p. 3)

On the one hand, "beneficial owner" may be construed in light of the...

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