News & Analysis as of

Canada Transfer Pricing

Davies Ward Phillips & Vineberg LLP

The CRA’s New Power to Compel Oral Interviews

The Canada Revenue Agency (CRA) can now require taxpayers or any other person to answer “all proper questions” and provide all reasonable assistance for any purpose relating to the administration or enforcement of the Income...more

Davies Ward Phillips & Vineberg LLP

Taxpayers Must Pay Interest on Non-Existent Tax Debts

In The Bank of Nova Scotia v The Queen, the Tax Court of Canada (TCC) considered how to calculate arrears interest on an audit adjustment that is offset by a loss carryback. ...more

Bennett Jones LLP

Canada's Federal Budget 2021 and International Trade Implications

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On April 19, 2021, the Federal Government of Canada unveiled its first budget in two years, promising over $100 billion in new spending intended to propel Canada's economic recovery from the COVID-19 pandemic. Part of the...more

Bennett Jones LLP

Transfer Pricing in the Time of COVID-19

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Many Canadian businesses have closed the books on their 2020 fiscal year, having faced an unprecedented economic shock wrought by the pandemic. 2020 fiscal year results will undoubtedly be affected, in many cases to the...more

Freeman Law

International Tax Treaty: Canada

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Quick Summary. In 1867, the United Kingdom passed a Parliamentary act establishing what is now known as Canada. Today, Canada, the largest country in the Western Hemisphere, is a federation of ten provinces and three...more

Bennett Jones LLP

Voluntary Disclosure to CRA—It Ain’t What It Used To Be

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It has now been two years since the new Voluntary Disclosures Program (VDP) rules came into effect, which restricted the relief that taxpayers had previously enjoyed. We recently submitted a request to the Canada Revenue...more

A&O Shearman

Central District Of California Sustains Putative Class Action Against Canadian Silver Company And Its Auditor For Failing To...

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On March 25, 2019, Judge Christina A. Snyder of the United States District Court for the Central District of California denied a motion to dismiss a class action filed against a Canadian silver company (the “Company”),...more

Bennett Jones LLP

VDP Overhaul Coming Sooner Than You Thought

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Earlier this month, we reported that a senior representative of the Canada Revenue Agency (CRA) had announced that it was "highly likely" that the incoming changes to the Voluntary Disclosures Program (VDP) would be delayed...more

Dorsey & Whitney LLP

Loans to U.S. Subsidiaries Should Be Carefully Structured and Documented to Obtain U.S. Tax Benefits

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Canadian companies should carefully structure and document loans and advances to their U.S. subsidiaries. If loans to U.S. subsidiaries are not properly structured and documented, such loans may be recharacterized as equity...more

Bennett Jones LLP

Is Your Customs Compliance BEPS Ready?

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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

Bennett Jones LLP

Doing Business in Canada

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Forms of Business Organization in Canada - Canadian business laws are well developed. Several different types of business structures are available in Canada. Each features unique advantages and disadvantages. ...more

Bennett Jones LLP

Transfer Pricing Customs Duty Refund Applications – Let’s Do it Right

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The Canada Border Services Agency (CBSA) has informed the Canadian importing community that importers may be entitled to obtain customs duty refunds in connection with downward transfer pricing adjustments having the effect...more

Bennett Jones LLP

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

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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

Bennett Jones LLP

Judicial Review Application Preserved in Transfer Pricing Penalty Case

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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

Bennett Jones LLP

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

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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

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