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…
AI in the Tax Department: Getting Tax a Seat at the Table Artificial intelligence (AI) is reshaping business functions rapidly, yet many…
TEI Roundtable No. 51: The Future Corporate Tax Department As tax moves into the future, in-house professionals are experiencing…
The Impact of AI in R&D Tax Credits For the last several years we’ve heard that artificial intelligence…
Making Sense of CAMT Complexity The corporate alternative minimum tax (CAMT) under Section 55 of…
Question: What Are the Key Updates in the FASB Income Tax Disclosure Requirements? In 2023, the Financial Accounting Standards Board (FASB) issued Accounting Standards…
Breaking Down Real-Time Controls in Global Tax As governments implement digital approaches to tax filing, reporting, operations,…