The Canada Revenue Agency (CRA) has announced that it will not seek leave to appeal the Federal Court of Appeal's decision in the BP Canada case. This means that the Court's decision to deny the CRA general and unrestricted...more
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
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