Matias Milet

Published Work

• “Applying Hybrid Entity Rules in the Canada-U.S. Treaty in a Transfer Pricing Context”, Tax Notes International, April 6, 2020 (co-authored with Roger Smith).
• Supreme Court of Canada Dismisses Taxpayer’s Appeal in Trust Residency Case, April 13, 2012.
• IBFD Tax News: Treaty between Canada and Barbados: Supreme Court of Canada – Decision on Trust Residence Case, April 16, 2012.
• 6^th Tax-Efficient Finance Structures Course: Tax Treaty Developments Impacting Cross-Border Financing, May 28, 2012.

• Presentation: Character Conversion Transactions and Synthetic Disposition Arrangements
• Tax Treaty Developments – 2014 NYSBA/OBA Legal Summit, March 28, 2014.
• Shades of Gray: Conrad Black’s International Tax Gambit, Tax Notes International, May 12, 2014.
• 7^th Annual U.S.-Latin America Tax Planning Strategies – Base Erosion Profit Sharing, June 5-6, 2014.
• Civil Unrest: Collective Investment Vehicles and the OECD, CCH International Tax, December 2014.
• Canada-U.S. Tax Treaty Issues: Anti-Hybrid Rules, the GAAR, and The U.S. Dual Consolidated Loss Rules, 63:12 Tax Notes Int’l (2011) (co-authored with Peter Repetto).
• Stripping Coupons, Filling Gaps: Proposed Amendments to Canadian Withholding Tax on Interest, 22:9 Journal of International Taxation (2011) (co-authored with Andrew S. McGuffin).
• Notional Expenses of a Permanent Establishment: the OECD Rewrites Article 7, XIV:1 Business Vehicles (2011) (co-authored with David Davachi).
• Hybrid Foreign Entities, Uncertain Domestic Categories: Treaty Interpretation Beyond Familiar Boundaries, 59:1 Cdn Tax J. 25 (2011).
• When Is a ‘Nothing’ Something? Canada’s Approach to Hybrid Entities Under the Canada-U.S. Treaty, 59:4 Tax Notes Int’l (2010).
• Canada Revenue Agency Considers Interpretation of Antihybrid Rule in Canada-U.S. Tax Treaty, 55:2 Tax Notes Int’l (2009).
• Canada (chapter), Permanent Establishments, International Bureau of Fiscal Documentation (The Netherlands), April 2009.
• New Limitations on Imposition of Interest Withholding Tax, Derivatives and Financial Instruments, March/April 2008 (co-authored with Amanda Heale).
• Permanent Establishments Through Related Corporations Under the OECD Model Treaty, 55:2 Cdn Tax J. 289 (winner of Douglas Sherbaniuk Distinguished Writing Award).