STARI Lunchtime Seminar - What Does ‘Source’ Really Mean? Re-Examining Source Rules in Double Tax Conventions
Most jurisdictions tax nonresidents only on their domestically sourced income. However, determining where income is sourced has been a longstanding headache for tax students, academics, policymakers, and industry stakeholders — though lawyers may view it as a bonanza. As Professor Avi-Yonah observed, source rules “are a wonderful thing for lawyers and something that causes economists to despair,” not least because “most tax economists today believe that income does not have a single source that can be pinpointed” (Avi-Yonah, 2007). Professor Arnold similarly notes that “the concept of source is poorly developed in domestic tax legislation and tax treaties” (Arnold, 2023).
Does “source” refer to the place where value is created, where goods or services are consumed, or where the outbound payment is made? A relatively common perception is that active income is sourced in the country where contributions to income generation occur, whereas passive income is sourced in the payor’s country. However, with the rapid…
Fee(s): Complimentary (Successful registrant will receive an email for confirmation of your registration). Contact: ccla@smu.edu.sg. Speaker Details: Dr Qiang Cai
Lecturer, School of Law
University of AberdeenDr Qiang Cai is a Lecturer in Tax Law and Commercial Law in the School of Law at the University of Aberdeen, where he also serves as Director of the Aberdeen Centre for Commercial Law. He has published extensively in the field of international tax law, with a particular interest in theorising the international tax system. His research adopts an interdisciplinary approach that integrates law, economics, and political theories. Qiang is a member of… RSVP: . Type: Seminars & Workshops. Subject: Law. Accounting. Audience: SMU Faculty & Staff. Current Student. Public. Academic Community. Professionals.
Thursday, January 29, 2026, 12:00 PM – 1:00 PM.
Function Lounge 4.02, Level 4
Singapore Management University
Yong Pung How School of Law
55 Armenian Street
Singapore 179943.
SGRI Seminar: New Frontiers in Insolvency Law: Towards a Contractualization of Financial Distress?
The length and costs of formal insolvency proceedings have encouraged regulators, policymakers, practitioners and scholars to explore alternative mechanisms for addressing financial distress. This event will examine the emerging trend toward the “contractualization” of financial distress, that is, a shift whereby parties increasingly structure financial restructuring and insolvency arrangements outside traditional court processes, as well as the growing need to providedebtors and creditors with greater flexibility to deal with financial distress. To that end, the event will discuss the rise of hybrid procedures, including pre-packaged reorganizations and pre-arranged sales of businesses, along with the strategies and regulatory conditions needed to facilitate out-of-court restructurings. It will also examine the use of arbitration in insolvency-related disputes, different approaches to the choice of insolvency forum, and how the use of AI may facilitate contractual solutions for the resolution of financial di…
Fee(s): Public: SGD92.65 per pax incl. 9% GST (non-refundable). Contact: ccla@smu.edu.sg. Speaker Details: You may refer to the Speakers Biography here. RSVP: . Type: Seminars & Workshops. Subject: Law. Audience: SMU Faculty & Staff. Current Student. Public. Academic Community. Professionals. Alumni.
Thursday, February 12, 2026, 2:00 PM – 6:45 PM.
Function Lounge 4.02, Level 4
Singapore Management University
Yong Pung How School of Law
55 Armenian Street
Singapore 179943.
For more info visit site.smu.edu.sg.