AuthorDavid Kerzner, David W. Chodikoff
The legal research that constitutes the foundation of this book began in 2009
as part of my doctoral degree at the Faculty of Law, Queen’s University, in
Kingston, Ontario, which was successfully completed in 2014. I am grateful for
the support of Associate Dean Sharry Aiken and Associate Dean Mark Walters,
of the Faculty of Law and the School of Graduate Studies at Queen’s University,
throughout this enormous undertaking. As a student, I deeply valued the tre-
mendous support of and encouragement from Sharry Aiken, Phyllis Reid, and
Rose M Silva at Queen’s University. I would also like to express my gratitude to
the family of the late Eric W Cross for their support of the memorial fellowship
in his name. I was especially fortunate for the commitment and involvement
during my PhD studies of two extraordinary teachers and scholars at Queen’s
University: the late Associate Dean Stan Corbett (of the Faculty of Law) and
Professor Daniel Thornton (of the Business School). The right words fail me
in expressing my gratitude to my supervisor, Professor Arthur Cockf‌ield, for
sharing his brilliance as a tax scholar with me on this project and his qualities
of humility, grace, and kindness as a mentor and guide on this long journey.
I would also like to say thank you to these individuals, who during the
course of this project generously of‌fered their guidance: Brian Arnold, Nathan
Boidman, Thomas Tung-Pi Chen, David Chodikof‌f, Tim Edgar, William Fla-
nagan, Neil Harris, Bobbe Hirsh, Jinyan Li, Alan Macnaughton, Philip Wright,
and Bruce Zagaris. I am especially in debt to the following individuals for
their comments on earlier drafts of this research: Allison Christians, Arthur
Cockf‌ield, John Freeman, Wanjiru Njoya, Jean Thomas, and Daniel Thornton.
They are not responsible, however, for any possible errors, or the opinions or
positions advocated, for which the authors are alone accountable.

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