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Research & Publications

SHAPING THE future.

Beyond practice — researching and writing on the evolution of Canadian tax law.

Current Research · LLM Thesis · Grade A · Approved

Tax Reform in Canada: Renovate or Reconstruct the Income Tax Act for Economic Equality

A Normative Comparative Analysis of Tax Reform, Tax Mix, and Redistribution in Germany and Estonia
Master of Laws · Schulich School of Law, Dalhousie University
Candidate 2027

My LLM dissertation asks whether Canada should renovate the existing Income Tax Act or pursue a more comprehensive reconstruction of its tax mix to better advance economic equality. Drawing on critical tax theory and a comparative analysis of Germany’s 2000 reform cycle and Estonia’s flat-rate, distributed-profit regime, the dissertation evaluates what model of reform best serves Canada’s constitutional, policy, and equity commitments. Canada has not undertaken a comprehensive review of its tax system since the Carter Commission of 1966. The research engages that gap directly — framing income tax reform not as a neutral exercise in administrative rationalization but as a question about whose interests the law serves and what values it should embody.

Publications
CRA Audit/Assessment Practices 2022
Co-authored with Andrew Plant · Atlantic Provinces Tax Conference, 2022, 9:1-35
Examines CRA audit procedures, Requirements for Information, and solicitor-client privilege for accountant work.
Wellness Expenses and Medical Expense Tax Credit
Tax Hyperion, Vol. 19, Issue 5, September–October 2022
Three-part publication on leveraging the non-refundable medical expense tax credit under s.118.2 for wellness therapies.
Filing a Joint Election for Spousal Rollover due to Marriage Breakdown
Tax Hyperion, Vol. 18, Issue 5, September–October 2021
Examines deeming rules and available exceptions including joint election for spousal rollover relief.
A Special Rule For A Specific Instance — Connected And Control
Tax Hyperion, Vol. 18, Issue 4, July–August 2021
Examines subsection 186(7) of the Income Tax Act regarding how “connected” should be interpreted.
Intercorporate Shareholdings and 110.6(15)(b) — Are You Offside?
Tax Hyperion, Vol. 18, Issue 2, March–April 2021
Planning considerations for QSBCS definitions and Lifetime Capital Gains Exemption access.
Would a ‘Book of Business’ Make a Business?
Tax Hyperion, Vol. 18, Issue 1, January–February 2021
Examines how a client list functions as a critical asset for service-based sole proprietors.
Employer Support for Employee Movement Within Canada
Tax Hyperion, Vol. 17, Issue 6, November–December 2020
Addresses employer handling of employee relocations and the three approaches to moving expenses.
The Redesigned Canada Emergency Wage Subsidy Program
Tax Hyperion, Vol. 17, Issue 4, July–August 2020
Examines Bill C-20 modifications to CEWS program revenue decline requirements.
The Client, Accountant and Lawyer: A Necessary Relationship
Tax Hyperion, Vol. 16, Issue 5, September–October 2019
Examines solicitor-client privilege for communications among lawyers, accountants, and clients in tax planning.
Topics of Interest
General Anti-Avoidance Rule (GAAR) Alternative Minimum Tax Expanded CRA Audit Powers Mandatory Disclosure Rules Trust Reporting Requirements Intergenerational Business Transfers

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