Trends and Developments in Canadian Tax Controversy and Jurisprudence
Transfer pricing issues, increases in voluntary disclosures, and procedural disputes are among major developments, but what will happen in 2016 — and beyond?
The Canada Revenue Agency (CRA) continues to employ a risk-based approach when auditing large corporate taxpayers, focusing on high-risk areas such as aggressive tax avoidance and international tax planning. Information-gathering involves the use of written requests and requirement letters to routinely attempt to compel delivery of taxpayer information. However, the…
New Developments in Canada’s General Anti-Avoidance Rule Editor’s note. This article was written in early May. In…
Oops! I Did It Again: Practical Implications of Revenue Procedure 2022-39 A fact, well known in the tax community: every tax…
TEI Roundtable No. 43: Separate, Combined, and Worldwide Unitary State Filings One of the most talked-about education sessions at this year’s…
Buying and Selling CFCs Under New Corporate Alternative Minimum Tax Regime As part of the Inflation Reduction Act, Congress enacted a…
AI, ETL Tools Offer Promising Possibilities Artificial intelligence (AI) and extract, transfer, and load (ETL) tools…
David Gillman David Gillman began his tax career at Peat Marwick, the…