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ARTICLE · 31 AUGUST 2023

Navigating Cross-Border Tax Controversy

Aird & Berlis LLP
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The Canada Revenue Agency ("CRA") has been steadily increasing the intensity of audits targeting cross-border investment and business activity.

CanadaTax
Louise Summerhill
Louise Summerhill
Christopher Slade
Christopher Slade
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The Canada Revenue Agency ("CRA") has been steadily increasing the intensity of audits targeting cross-border investment and business activity.

Your Tax Controversy/Tax Litigation team at Aird & Berlis has deep experience navigating all types of disputes that can arise in this area, including:

  • Transfer pricing. We are currently acting on complex transfer pricing disputes, including a Tax Court appeal involving a public multinational pre-acquisition reorganization and a Tax Court appeal involving a cross-border hybrid financing structure.
  • Transfer pricing – downward adjustments. Our lawyers successfully resolved a dispute involving the denial of over $400M of downward transfer pricing adjustments under subsection 247(10) of the Income Tax Act via judicial review in Federal Court.

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