Taxation

Transfer Pricing

Transfer pricing & APA considerations during an economic disruption

Mark Kirkey of Gowling WLG on transfer pricing in the new economic reality
Profession

Suing the Canada Revenue Agency for negligence

Upper level costs awarded to CRA in lengthy accounting case over SR&ED credits
Practice

The Tax Court Of Canada tests a new procedure – The Preliminary Ruling Docket

2020 initiative driven by increased objections, case backlog
Thought Leaders

Put your trust in taxes during the coronavirus pandemic recovery

Governments amend taxes for good times and bad, says Andrew Bauer
Practice

Crown bound by settlement agreement to allow losses it claimed to be a fiction

Gergely Hegedus of Dentons Canada on a recent Federal Court of Appeal decision
Practice

1074022 B.C. Ltd. v. Li: The need for legislative reform

A misinterpretation of section 116 of the Income Tax Act in a BC real estate case
Profession

Coronavirus tax relief: Finally some good news for accountants

Sole practitioners, small firms will benefit most from deadline extensions
Profession

CRA further circumscribes trust 21-year planning strategies involving non-resident beneficiaries

The CRA's stated positions will result in a chill on tax practitioners' advice to their clients, says Stephen Sweeney of Miller Thomson
Practice

Scott v The Queen: The importance of evidence

How two brothers came under the scrutiny of the Tax Court of Canada
Thought Leaders

Inheritance tax, wealth tax and more capital gains tax: The future of Canadian taxation?

Canadian tax policy has become a hotbed of new ideas, writes Margaret O'Sullivan
Practice

Donor Beware: The pitfalls of participating in a donation tax shelter

The Tax Court of Canada case Abreo v. The Queen
Thought Leaders

Ottawa should forget about limiting interest expense deductibility

Allan Lanthier on the OECD's proposal to limit excessive debt leveraging