393 results found

On April 29, 2022, the Department of Finance released the first of two packages of draft legislation to implement its proposals to eliminate the tax benefits of certain hybrid mismatch arrangements.

On June 21, 2022, the Canada Revenue Agency (CRA) replaced its Transfer pricing memorandum (TPM) on downward transfer pricing adjustments, TPM-03 dated October 20, 2003, with the revised TPM-03R.

Record vehicle sales around the world have been motivated, in large part, by expanding global trade agreements that make the buying and selling of automobiles relatively easy.

On March 26, 2025, the Tax Court of Canada (the "Tax Court") held that it lacked jurisdiction to hear an appeal from MEGlobal Canada ULC (the "Taxpayer").

Sanity prevailed in a recent Federal Court ("FC") decision involving an application by the Minister of National Revenue ("Minister") to compel a taxpayer to produce approximately 25 employees...

The Canada Revenue Agency (the "CRA") has launched roughly 100 audits into taxpayers named in the Paradise Papers offshore tax leak, according to documents tabled in Parliament.

Under section 247 of the ITA, the CRA can adjust the terms and conditions of cross-border transactions between a Canadian taxpayer and a non-arm's length party.

A separate section of the ITA governs how many tax years remain open for reassessment, for example, as resulting from a CRA tax audit.

Tax executives and practitioners familiar with administrative procedures under the Canadian <I>Income Tax Act</I> (the "Act") are aware of the broad powers afforded the Canada Customs and Revenue Agency ("CCRA") to conduct audits, to compel the production of books and records and even to obtain and execute search warrants

The Québec Budget tabled on March 17, 2016, (the "Budget") announces significant changes to the regime governing the duties on the transfer of real property (immovables) in Québec.

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

For tax geeks like me, the OECD’s BEPS project has been fascinating to watch and participate in the debate.

On March 26, 2026, Canada's new transfer pricing rules received royal assent and will have a significant impact on multi-national enterprises (MNEs) in life sciences industries.

During any type of tax dispute resolution process, a taxpayer's priority should always be to meet the deadlines prescribed by the relevant legislation.

Transfer pricing economists must consider various transfer pricing methodologies when assigning intercompany profits to related parties.

The evolving landscape of U.S. tariffs and Canadian countermeasures presents significant challenges for multinational groups...

Navigating the complex landscape of corporate taxes in Canada can be a daunting task for any business. At Rosen & Associates Tax Law, we understand the intricacies of the Canadian tax system and are dedicated...