Tax: M&A, Reorganizations and Restructuring Transactions Tax: M&A, Reorganizations and Restructuring Transactions

Federal Court of Appeal denies CRA routine access to tax accrual working papers

The Federal Court of Appeal's decision in BP Canada Energy Company v. MNR (2017 FCA 61) deals with whether the Minister of National Revenue could...

The U.S. “Big Border Tax”: A primer for Canadians

If enacted, the Blueprint proposals would represent a tectonic shift in the U.S. taxation system by effectively repealing the income tax and...

Are private equity and other collective investors entitled to tax treaty benefits?

The OECD released a discussion draft with examples intended to clarify when private equity and other investors will be entitled to tax treaty...

Supreme Court of Canada clarifies the remedy of rectification in Canadian tax cases

On December 9, 2016, the Supreme Court of Canada released two much-awaited decisions in Fairmont and in PJC that clarified the scope of the remedy...

Significant tax treaty changes proposed in multilateral convention

The OECD released a multilateral convention (MLI) together with a detailed explanatory statement. Once in effect, the MLI may have a significant...

Proposed GST/HST amendments relating to drop shipments

The drop shipment rules essentially allow an unregistered non-resident person to acquire goods in Canada on a tax-free basis provided the goods are...

Applying the TPSM in Canada

The discussion draft on the application of the Transactional Profit Split Method (TPSM) presents the TPSM as a multi-sided transfer pricing method.

Canadian transfer pricing documentation: What you should know

The two transfer pricing memoranda released by the Canadian Revenue Agency on January 29, 2015 address intra-group services (TPM-15) and multi-year...

Managing Canadian investment entities in the U.S.

Investment entities in the United States that happen to reside in Canada now have detailed guidance for determining their status under the Foreign...