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…
How To Bind Without Getting in One: Avoiding Controversy Over Signature Authority Issues
It’s late in the day. After weeks of review, it’s time to file an entity classification election for an entity in your company’s structure. The election is due today. You have already carefully analyzed the ramifications of the election. Form 8832 has been drafted, reviewed, and approved. All that is… Read more »
Transfer Pricing: Are We in a Global Tax War?
Expect Controversy To Heat Up in Light of BEPS
Transfer pricing. This is one of the most complex and controversial areas of corporate tax, occupying considerable time and energy on the part of many of TEI’s members, especially in the last twelve months. What exactly is transfer pricing? According to Mike Patton and Eric Ryan, partners at the law…
Why Unclaimed Property Risk Management Is on the Menu in 2022 Every state has adopted an unclaimed property (or escheat) law,…
Obtaining IRS Refunds: Procedures and Strategies Uncertainty in tax law is reaching unprecedented levels. In the…
The Evolving Landscape of Cross-Border Tax Examination Our clients and our practice group members are increasingly occupied…
Much Ado, but Little New: A Guide to Section 951(a) After Build Back Better The definition of “pro rata share” in Section 951(a)(2) is…
New Frontiers of Dispute Settlement in a Pillar One World—Part One Over the past several decades, the seemingly discrete disciplines of…
TEI Roundtable No. 37: Lessons Learned From TCJA Implementation This roundtable was conducted on October 27 as the closing…