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…
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…