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Professor Tim Edgar

Profile


Degrees

BA LLB UWO LLM York(Canada) PhD Deakin


Courses Taught

  • Comparative Taxation of Financial Transactions
  • Comparative Income Tax


Areas of Interest

  • Tax treatment of financial instruments and financial institutions


Brief Biographical Detail

Tim Edgar is also a professor at the Faculty of Law, The University of Western Ontario, London, Canada. Before that, he was an associate with Stikeman, Elliott LLP in Toronto. He has also served as a consultant to the Canadian Department of Finance, the Canada Revenue Agency, the Auditor General of Canada, the International Monetary Fund, the Organisation for Economic Co-operation and Development, the Australian Treasury Department, and the Australian Taxation Office. He was also a senior policy advisor with the Policy Advice Division of New Zealand Inland Revenue. Professor Edgar has published numerous articles in the Canadian Tax Journal and other periodicals and is co-editor of the Current Tax Reading feature of the journal. He is author of The Income Tax Treatment of Financial Instruments: Theory and Practice, published by the Canadian Tax Foundation.

Publications

Books | Edited Books | Book Chapters | Case Book Chapters | Journal Articles | Published Conference/Seminar Proceedings | Reviews and Commentaries | Published Government/Commission Reports


Books

  • Edgar, T, Income Tax Treatment of Financial Instruments: Theory and Practice, Canadian Tax Paper No. 105, Canadian Tax Foundation: Toronto (2000)

Edited Books

  • Edgar, T, Sandler, D & Cockfield A, Materials on Canadian Income Tax (14th edition), Carswell: Scarborough Ontario (2010)
  • Edgar, T, Materials on Canadian Income Tax (13th edition) (with D Sandler), Carswell: Scarborough Ontario (2005)
  • Edgar, T, Materials on Canadian Income Tax (12th edition) (with J Li and D Sandler), Carswell: Scarborough Ontario (2000)
  • Edgar, T, Materials on Canadian Income Tax (11th edition) (with B Arnold, J Li and D Sandler), Carswell: Scarborough Ontario (1996)
  • Edgar, T, Materials on Canadian Income Tax (10th edition) (with B Arnold and J Li), Carswell: Scarborough Ontario (1993)
  • Edgar, T, Materials on Canadian Income Tax (9th edition) (with B Arnold), DeBoo: Don Mills, Ontario (1990)

Book Chapters

  • Edgar, T, ‘Outbound Direct Investment and the Sourcing of Interest Expense for Deductibility Purposes’ in Arthur J. Cockfield (ed), Globalization and Its Tax Discontents: Tax Policies and International Investments: Essays in Honour of Alex Easson, University of Toronto Press: Toronto (2010) 60-83
  • Edgar, T, ‘The Taxation of Financial Arrangements (TOFA) Legislation: Is There Work Left to be Done?’ in Rick Krever and Chris Evans (eds), Australian Business Tax Reform in Retrospect and Prospect, Thomson Reuters: Sydney (2009) 341-366
  • Edgar, T, ‘Designing and Implementing a Target-Effective General Anti-Avoidance Rule’ in D Duff and H Erlichman (eds), Tax Avoidance in Canada after Canada Trustco and Mathew, Irwin Law: Toronto (2007) 221-58
  • Edgar, T, ‘The Search for Alternatives to the Exempt Treatment of Financial Services under a Value-Added Tax’ in R Krever and D White (eds), GST in Retrospect and Prospect, Brookers Publishing: Auckland (2007) 131-61
  • Edgar, T, ‘The Concept of Taxable Consumption and the Deductibility of Expenses Under an Ideal Personal Income Tax Base’ in R. Krever (ed), Tax Conversations: A Guide to the Key Issues in the Tax Reform Debate - Essays in Honour of John G Head, International Bureau of Fiscal Documentation: Amsterdam (1997) 293-363
  • Edgar, T, ‘The Debt-Equity Distinction Underlying the Taxation of Financial Instruments: Past Practice and Future Policy Directions in Australia and Canada’ in J Head and R Krever, (eds), Taxation Towards 2000, Australian Tax Research Foundation: Sydney (1997) 393-435

Case Book Chapters

  • Edgar, T, ‘Source Concept of Income’ (with M O’Brien) in T Edgar and D Sandler (eds) Materials on Canadian Income Tax (13th editions), Caswell: Toronto (2005) Chapter II
  • Edgar, T, ‘Source Concept of Income’ (with M O’Brien) in T Edgar, J Li, and D Sandler (eds), Materials on Canadian Income Tax (12th editions), Caswell: Toronto (2000) Chapter II
  • Edgar, T, ‘Taxation of Intermediaries’ (with B Arnold) in Materials on Canadian Tax (9th, 10th and 11th editions), Caswell: Scarborough, Ontario (1990, 1993, 1996) Chapter VIII

Journal Articles

  • Edgar, T, ‘Financial Instability, Tax Policy, and the Tax Expenditure Concept’ (2010) 63(3) SMU Law Review 969-1032
  • Edgar, T, ‘Foreign Direct Investment, Thin Capitalization, and the Interest Expense Deduction: A Policy Analysis’ (with J Farrar and A Mawani) (2008) 56(4) Canadian Tax Journal 803-869
  • Edgar, T, ‘Building a Better GAAR’ (2008) 27(4) Virginia Tax Review 833-905
  • Edgar, T, ‘Stapled Securities – "The Next Big Thing" in Income Trusts? Useful Lessons from the US Experience with Stapled Shares’ (with R Avi-Yonah and F Shaheen) (2007) 55(2) Canadian Tax Journal 247-288
  • Edgar, T, ‘Canadian Income Trust Saga: Over, or Headed for a Junk Bond Phase?’ (2007) 45(8) Tax Notes International 755-767
  • Edgar, T, ‘The International Income Taxation of Portfolio Debt in the Presence of Bi-Directional Capital Flows’ (with E McCann) (2006) 4(1) eJournal of Tax Research 5-24
  • Edgar, T, ‘Source Taxation and the OECD Project on the Attribution of Profits to Permanent Establishments’ (with D Holland) (2005) 37(6) Tax Notes International 525-539
  • Edgar, T, ‘Interest Deductibility Restrictions - Expecting Too Much from REOP?’(2004) 52(4) Canadian Tax Journal 1130-1172
  • Edgar, T, ‘The Trouble with Income Trusts’ (2004) 52(3) Canadian Tax Journal 819-852
  • Edgar, T, ‘The Significance of Competitive Market Constraints for the Treatment of Financial Services Under a Value Added Tax’ (with E. McCann) (2003) 30(3) Tax Notes International 791-808
  • Edgar, T, ‘Corporate Income Tax Coordination as a Response to International Tax Competition and International Tax Arbitrage’ (2003) 51(3) Canadian Tax Journal 1079-1258
  • Edgar, T, ‘At-Risk Rules as a Legislative Response to "Abusive" Personal Tax Shelters’ (2001) 7(2) New Zealand Journal of Taxation Law and Policy 291-321
  • Edgar, T, ‘Exempt Treatment of Financial Intermediation Services under a Value Added Tax: An Assessment of Alternatives’ (2001) 49(5) Canadian Tax Journal 1133-1219
  • Edgar, T, ‘Financial Innovation and the Tax Avoidance Lottery: A View from North America’(2000) 6(2) New Zealand Journal of Taxation Law and Policy 63-102
  • Edgar, T, ‘Some Lessons from the Saga of Weak-Currency Borrowings’ (2000) 48(1) Canadian Tax Journal 1-34
  • Edgar, T, ‘The Taxation of Financial Arrangements (TOFA) Proposals: A Modest and Defensible Agenda for Reform’ (2000) 23(2) University of New South Wales Law Journal 288-98 and (2000) 6(2) University of New South Wales Law Journal Forum 28-33
  • Edgar, T, ‘The Concept of Interest Under the Income Tax Act’ (1996) 44(2) Canadian Tax Journal 277-347
  • Edgar, T, ‘Deduction of Interest’ (with B Arnold) (1995) 43(5) Canadian Tax Journal 1216-1244
  • Edgar, T, ‘Integration Canadian Style: Comments on the Dividend Tax Credit and the Recommendation of the Ontario Fair Tax Commission’ (1994) 9(16) Tax Notes International 1231-1254
  • Edgar, T, ‘Distress Preferred Shares and Small Business Development Bonds: A Tax Expenditure Analysis’ (1994) 42(3) Canadian Tax Journal 659-708
  • Edgar, T, ‘The Draft Legislation on Interest Deductibility: A Technical and Policy Analysis’ (with B Arnold) (1992) 40(2) Canadian Tax Journal 267-303
  • Edgar, T, ‘Deemed Realization of Trust Property: Proposed Amendments to the 21-Year Rule’ (1992) 11(3) Estates and Trusts Journal 207-243
  • Edgar, T, ‘The Thin Capitalization Rules: Role and Reform’ (1992) 40(1) Canadian Tax Journal (1992) 1-54
  • Edgar, T, ‘The Classification of Corporate Securities for Income Tax Purposes’ (1990) 38(5) Canadian Tax Journal 1141-1188
  • Edgar, T, ‘Reflections on the Submission of the CBA/CICA Joint Committee on Taxation Concerning the Deductibility of Interest’ (with B Arnold) (1990) 38(4) Canadian Tax Journal 847-885
  • Edgar, T, ‘The Corporate Interest Deduction and the Financing of Foreign Subsidiaries’ (1987) 4(4) Australian Tax Forum 491-528

Published Conferences/Seminar Proceedings

  • Edgar, T, ‘The Tax Treatment of Interest and Financing Charges in a World of Financial Innovation: Where Should We be Going?’ in Current Issues in Corporate Finance:1997 Corporate Management Tax Conference, Canadian Tax Foundation: Toronto (1998) 10:1-57
  • Edgar, T, ‘Deduction of Loan Losses and Financing Expenses by Moneylenders’ in Report of Proceedings of the Forty-Sixth Tax Conference: 1994 Conference Report, Canadian Tax Foundation: Toronto (1995) 16:1-51
  • Edgar, T, ‘Interest Deductibility’ (with B. Arnold) in R. Hogg and J. Mintz (eds), Tax Effects on the Financing of Medium and Small Public Corporations: Policy Forum Series no. 27, John Deutsch Institute for the Study of Economic Policy, Queen’s University: Kingston, Ontario (1992) 59-78

Reviews and Commentaries

  • Edgar, T, ‘Response: A Defensible and Workable Approach to the Income Tax Treatment of Financial Instruments’ (2002) 50(1) Canadian Tax Journal 249-60
  • Edgar, T, ‘Australia Releases Issues Paper on Taxation of Financial Arrangements’ (1997) 14(4) Tax Notes International 327-38
  • Edgar, T, ‘Canadian Courts Consider the Meaning of Income Under the Income Tax Act’ (with B. Arnold) (1996) 13(6) Tax Notes International 401-03
  • Edgar, T, ‘The Tax Treatment of Interest Under the Basic World Tax Code’ (1993) 7(5) Tax Notes International 347-55

Published Government/Commission Reports

  • Interest Deductibility Restrictions and Inbound Direct Investment, Ottawa: Advisory Panel on Canada’s System of International Taxation, Background Report (October 2008)