Shrinking Tax Sovereignty In Canada? Evidence From the Income Tax Act

Authors

• Jinyan Li, Osgoode Hall Law School of York UniversityFollow
• Angelo Nikolakakis, Ernst & Young Law LLP

Document Type

Article

Publication Date

2026

Source Publication

2026 Canadian Tax Journal, special issue on Tax Sovereignty in a Digital and Divided World, forthcoming

Keywords

Tax sovereignty; income tax act, Canada-US relations, Tax Reforms

Abstract

This paper explores the questions of whether Canadian tax sovereignty has changed, and if so, how and why through examining the Income Tax Act in terms of the major legislative changes and their underlying influences. It finds that while maintaining formal, independent sovereignty, Canada has always borrowed foreign ideas, rules and policies when they serve Canadian interests and has recently adopted a more coordinated approach in tackling international tax challenges.

Comments

We thank Jessica (Jiulu) Gan and Fukun Yang, Osgoode JD candidates, for their excellent research assistance. We thank Shawn Porter, Sophie Chatel and David Duff for their comments on an earlier version of this paper.  

Repository Citation

Li, Jinyan and Nikolakakis, Angelo, "Shrinking Tax Sovereignty In Canada? Evidence From the Income Tax Act" (2026). Articles & Book Chapters. 3423.
https://digitalcommons.osgoode.yorku.ca/scholarly_works/3423