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…
The Burgeoning Importance of E-Invoicing Although the United States has not yet officially adopted e-invoicing,…
The Presumption of Correctness A common question tax directors ask when considering whether to…
Technical Corrections to the 2021 Final Foreign Tax Credit Regulations As readers are well aware, almost a year ago, on…
TEI Roundtable No. 40 Foreign Tax Credit Regulations For almost four decades, the foreign tax credit regulations have…
Reconnecting at TEI’s Annual Conference I am very excited about TEI’s 77th Annual Conference, as…
Steve Saunders Steve Saunders gained an appreciation of the complexity of tax…