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Tax Tips

Oct 03, 2016

Canadian Tax Treatment of Certain Florida and Delaware Partnerships

the CRA views these entities to be corporations for Canadian… Read more »

Jul 20, 2016

Upstream Loans

taxpayers may need to act now  Prior to 2011, upstream… Read more »

Jan 11, 2016

Voluntary Disclosures – Time is of the Essence

“the initial submission can be made quickly, on a no-names… Read more »

Transfer Pricing Newsletter

Dec 15, 2016

Is the CRA skipping dinner in the hope of getting its deserts? Digesting the “new” Canadian transfer pricing documentation standard

The CRA was recently asked “Will the CRA’s expectations of… Read more »

Sep 20, 2016

A new way to do the splits: BEPS draft guidance falls short of enabling global formulary apportionment

This article also appears in INSIGHTS vol 3 no 7… Read more »

Jun 17, 2016

Mind the $2 billion gap – Medtronic decision for the taxpayer favors pricing transactions over profit split

The U.S. Tax Court recently decided for the taxpayer in… Read more »