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On the Ice with Artificial Intelligence

Taking Wayne Gretzky's famous advice—"skate to where the puck is going, not where it has been"—will get easier for businesses that embrace artificial intelligence (AI). That's the conclusion I drew from a sold-out event...more

No Routine Access by CRA to Tax Working Papers Rules the Federal Court of Appeal

The Federal Court of Appeal has limited the Canada Revenue Agency's (CRA) access to tax accrual working papers that reveal a taxpayer's uncertain tax positions. This case is an important one for every company that has audited...more

Is Your Customs Compliance BEPS Ready?

2016 was the first year of the new transfer pricing reporting regime called Country-by-Country Reporting (CbCR). It will be a major new tool for revenue authorities and will undoubtedly lead to greater audit activity and more...more

What Trump’s Tax Plan Means For Canada

The election of Donald Trump combined with Republican control of Congress means that U.S. tax reform has suddenly gone from totally impossible to highly likely. The specifics of that reform are not known but the...more

Tax Uncertainty Hinders Global Growth: Business Survey Launched

Businesses are invited to participate in an international survey from the OECD to measure the impact of tax uncertainty on their investment decisions. Companies have until December 16 to participate in a confidential...more

Tax Court Allows Deduction for Advisory Fees in M&A Transaction

The Tax Court of Canada has recognized in a recent case that “oversight expenses” – notably investment banking and other professional advisory fees for services rendered to boards of directors in their discharge of oversight...more

Key Policy Initiatives from Canada's New Liberal Government You Need to Anticipate

The Canadian election last week (October 19) produced a new government under Liberal Party leader Justin Trudeau. Defying speculation of a minority government, the Liberals won a clear majority, defeating the NDP and Stephen...more

CRA Releases Important Transfer Pricing Guidance on Management Fees and Other Intra-Group Services

CRA recently released a new Transfer Pricing Memorandum (TPM-15) giving detailed guidance on CRA’s audit approach to management fees and other charges for intra-group services, including on allocation keys for indirect...more

Canadian Customs Authority Shifts Gears on Import Duty Refunds

The CBSA has made a long-sought-for change in its policy to allow duty refunds in the event of qualifying downward transfer price adjustments by importers. The change comes on the heels of victory by Bennett Jones in a test...more

Canadian Importers May Now Seek Import Duty Refunds

Since the introduction of the Transaction Value System of customs valuation by Canada on January 1, 1985, the Canada Border Services Agency (CBSA) has maintained a stated policy of denying refund claims of related party...more

1/19/2015  /  Canada , CBSA , Customs , Duties , Importers , Imports

BEPS Tail Shouldn’t Wag Global Investment Dog

I spoke recently on a panel in Tokyo on the future of international tax planning after BEPS (the OECD’s & G20’s Action Plan to counter Base Erosion & Profit Shifting). The panel also featured a senior official at the OECD and...more

11/18/2014  /  BEPS , Canada , G20 , OECD , Tax Planning

BC LNG Tax Regime: Rate Concessions and New Tax Credit but Uncertainty Remains

On October 21, 2014, the British Columbia government introduced Bill 6, the Liquefied Natural Gas Income Tax Act (LNGITA). The LNGITA proposes a two-tier tax on income derived from liquefaction activities at liquefied natural...more

Judicial Review Application Preserved in Transfer Pricing Penalty Case

A recent Federal Court of Appeal (FCA) case illustrates how contentious transfer pricing disputes can be – even one a taxpayer believed had been resolved! It also represents a rare situation in which the taxpayer’s...more

Revised CRA Policy Heralds Focus on Contemporaneous Transfer Pricing Documentation

CRA released an updated transfer pricing memorandum, TPM-05R, Requests for Contemporaneous Documentation, in March, which describes the procedural aspects of transfer pricing documentation requirements in substantially more...more

Tax Effective Use by Canadian Online Retailers of Bermuda Operations for International Expansion - 2011 Canada-Bermuda Tax...

E-tail Foreign Market Opportunity - The growth of online retail sales has globally outstripped the growth of all other retail channels, including during the last recession. For example, in England during 2012, it has...more

Businesses Face More Onerous Transfer Pricing Documentation and Country-by-Country Tax Reporting

The OECD proposes to reform transfer pricing documentation for multinational enterprises and to impose onerous country-by-country (CbC) reporting obligations, including disclosure of taxes paid in each country in which a...more

Taxpayer Loses Canadian Transfer Pricing Case

A recent transfer pricing case from the Tax Court of Canada (McKesson Canada Corporation v The Queen) establishes a broad interpretation of the “regular” (non-recharacterization) transfer pricing rule in the Income Tax Act...more

Supreme Court Endorses Key Tax Principle: Tax Law Should Follow Private Law Agreements

The Supreme Court of Canada recently endorsed a fundamental principle in Canadian tax law – namely that absent sham or statutory recharacterization rules, “tax law applies to transactions governed by, and the nature and legal...more

OECD Launches Action Plan on Base Erosion and Profit Shifting

The OECD released its Action Plan on Base Erosion and Profit Shifting (BEPS) on Friday. The BEPS initiative was launched earlier this year at the request of the G20 to counter alleged abuses by multinational corporations to...more

OECD Revising Intangibles Transfer Pricing Discussion Draft

At the OECD International Tax Conference in DC on June 3 and 4, Joe Andrus, Head of the OECD’s Transfer Pricing Unit, announced that the OECD’s Discussion Draft on Intangibles released in 2012 is under revision in two key...more

6/11/2013  /  Intangible Property , OECD

International Tax & Transfer Pricing Strategies in the Crosshairs

The OECD recently issued a report targeting corporate tax planning and transfer pricing strategies, which it asserts constitute a serious risk to tax revenues, tax sovereignty among nations and tax fairness. (OECD (2013),...more

Marketing Intangibles in International Transfer Pricing

An Indian tax appellate tribunal has recently ruled on the issue of marketing intangibles in a transfer pricing case involving the Indian manufacturing and sales subsidiary of the Korea-based LG Electronics Inc. In that case,...more

Supreme Court of Canada Establishes Important Principles in Transfer Pricing

The Supreme Court of Canada recently released its judgment in The Queen v Glaxo Smith Kline Inc.,1 (Glaxo), which is the Court's first pronouncement on Canada's transfer pricing rules. Transfer pricing involves the allocation...more

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