Jesse Brodlieb

Jesse Brodlieb

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Marzen: Tax Court Upholds Transfer Pricing Adjustments

The decision of the Tax Court of Canada in Marzen Artistic Aluminum Ltd. v. The Queen (2014 TCC 194) is the latest addition to a growing body of Canadian judgments on the application of the transfer pricing rules in section...more

6/18/2014 - Income Tax Act Tax Court Transfer Pricing

Spruce Credit: Avoidance transactions and the Duke of Westminster

In Spruce Credit Union v. The Queen (2014 FCA 143) the Federal Court of Appeal upheld the lower court’s interpretation and application of the inter-corporate dividend deduction under subsection 112(1) of the Income Tax Act...more

6/13/2014 - Appeals Canada CRA Credit Unions Dividends GAAR Income Tax Act Tax Avoidance Tax Court Tax Deductions

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