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Osler, Hoskin & Harcourt LLP
On February 21, 2024, the Canada Revenue Agency (CRA) published a revised Information Circular (Circular) on the Advance Pricing Arrangement (APA) program.
Osler, Hoskin & Harcourt LLP
On February 19, 2024, the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) released a report on Amount B (Amount B Report) that provides guidance on the simplified...
McCarthy Tétrault LLP
Throughout 2023, the Government of Canada continued its agenda of major tax reform with new legislative proposals and technical amendments to Canadian tax law affecting the general anti-avoidance rule (GAAR), clean economy tax credits, mandatory disclosure rules, and many more.
Sorbara Law
When software companies license or "sell" into Canada from abroad, there is often some leeway in how they allocate their fees between the license itself and related services.
Blake, Cassels & Graydon LLP
On November 21, 2023, the Minister of Finance (Minister) released Canada's 2023 Fall Economic Statement (FES). The primary focus of the FES is on affordability measures for Canadians...
Aird & Berlis LLP
The Canada Revenue Agency ("CRA") has been steadily increasing the intensity of audits targeting cross-border investment and business activity.
Osler, Hoskin & Harcourt LLP
Finance released a consultation paper on June6, 2023 proposing to rewrite Canada's transfer-pricing rules. The draft amendments incorporate base erosion and profit shifting (BEPS) concepts...
Osler, Hoskin & Harcourt LLP
The Department of Finance released a consultation paper on Canada's transfer pricing rules on June 6, 2023. This consultation was first announced in Budget 2021 following the Supreme Court's...
Osler, Hoskin & Harcourt LLP
On July 11, 2023, the OECD/G20 Inclusive Framework on BEPS approved a four-part Outcome Statement on the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation...
Gowling WLG
This article discusses the Department of Finance Canada's proposed legislative changes to section 247 of the Income Tax Act (Act), introduced to eliminate certain perceived issues with the current legislation...
Osler, Hoskin & Harcourt LLP
On June 6, 2023, the Department of Finance released a consultation paper on Canada's transfer pricing rules.
Gowling WLG
With the Canada Revenue Agency (CRA) deploying massive resources to crack down on perceived tax avoidance, it's now more important than ever to stay up to date with new CRA policies...
Miller Thomson LLP
There are more transfer pricing disputes making their way to court in Canada. Here, transfer pricing disputes have been primarily resolved through one of two methods...
Miller Thomson LLP
The rules governing transfer pricing in Canada are primarily contained in Section 247 of the Income Tax Act (Canada) (ITA). Subsection 247(2) of the ITA provides that when a Canadian taxpayer...
Borden Ladner Gervais LLP
On Feb. 23, 2023 and March 16, 2023, the Supreme Court of Canada (SCC) granted leave to appeal in two important cases considering the jurisdiction of the Tax Court of Canada
Rotfleisch & Samulovitch P.C.
Islamic or 'halal' financial products are growing globally and this is being driven by the peculiarity of these products in closing financial exclusion gaps affecting Muslims around the globe.
McMillan LLP
McMillan LLP is pleased to present our podcast series "Black History, Black Futures," which will be released throughout February as part of our Black History Month commemoration.
Davies Ward Phillips & Vineberg
The Canada Revenue Agency (CRA) can now require taxpayers or any other person to answer "all proper questions" and provide all reasonable assistance for any purpose relating to the administration...
Osler, Hoskin & Harcourt LLP
In 2022, the federal government released draft legislation to adopt many of the OECD's BEPS recommendations, including those related to interest deductibility, anti-hybrid measures and mandatory disclosure.
Gowling WLG
With the Canada Revenue Agency deploying massive resources to crack down on perceived tax avoidance, it's now more important than ever to stay up to date with new CRA...
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