Vitaly Timokhov, B.A., L.L.B., LL.M.


Tel: 416-847-7300

Publications of Vitaly Timokhov

Treatise on the Canada-U.S. Income Tax Convention

Vitaly is a principal author and Canadian editor of the Tax Advisor’s Guide to the Canada – U.S. Tax Treaty, a 2-volume loose-leaf published by Carswell Thomson. 

For more information, see


Vitaly has also authored 22 articles on taxation, corporate and commercial law published in academic and professional publications in the United States, United Kingdom, the Netherlands, and Australia. Vitaly’s articles include:

  • “The Future of Hybrid Entities in International Tax Law: Dehybridization and Anti-Abuse Function of Tax Treaties and Domestic Law in Cross-Border Transactions” 36 TAX NOTES INTERNATIONAL 457 – comparative analysis of the use of domestic tax laws and bilateral tax treaties as a tool preventing the abuse of hybrid entities.
  • “Enforcing Tax Judgments Across Borders: How Collection Assistance Can Overcome Limitations of the “Revenue Rule,”” 6 JOURNAL OF INTERNATIONAL TAXATION 36 (2003) – a comprehensive review of cross-border collection of taxes by U.S. and Canadian tax authorities.
  • “Using the U.S. Foreign Tax Credit System as an Investment Incentive in Developing Economies”, 26 TAX NOTES INTERNATIONAL 775 (2002). – economic and legal analysis of certain deficiencies of US foreign tax credits resulting in locking earnings and profits from resource earnings in off-shore jurisdictions.