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  • Article

    Canada Emergency Wage Subsidy: TPM-17 And Transfer Pricing Considerations

    On March 2, 2016, the Canada Revenue Agency ("CRA") released Transfer Pricing Memorandum 17 "The Impact of Government Assistance on Transfer Pricing" ("TPM-17").
    CanadaTax
    Gowling WLG
    Gowling WLG
  • Article

    Finance Canada Proposes Largest Overhaul Of Canadian Transfer Pricing Legislative Framework

    This article discusses the Department of Finance Canada's proposed legislative changes to section 247 of the Income Tax Act (Act), introduced to eliminate certain perceived issues with the current legislation...
    CanadaTax
    Gowling WLG
    Gowling WLG
Article

Supreme Court Of Canada Establishes Important Principles In Transfer Pricing

The Supreme Court of Canada recently released its judgment in The Queen v Glaxo Smith Kline Inc., (Glaxo), which is the Court’s first pronouncement on Canada’s transfer pricing rules.
CanadaTax
Bennett Jones LLP
Bennett Jones LLP
  • Article

    Developments in International Cartel Enforcement

    Cartel enforcement proceedings have increased exponentially in recent years, due to the introduction of competition laws in new jurisdictions, greater cooperation and coordination among international competition law authorities and especially, the proliferation of effective amnesty, leniency and immunity programmes (‘Leniency Programmes’). Leniency Programmes in particular are quickly becoming synonymous with anti-cartel enforcement to international authorities. Members of the International Comp
    CanadaAntitrust/Competition Law
    Dentons Canada LLP
    Dentons Canada LLP
  • Article

    2025 Tax Controversy Year In Review: A New Government And A Taxing Authority With More Power

    2025 will be remembered as a year of transition for Canadian taxpayers.
    CanadaTax
    Blake, Cassels & Graydon LLP
    Blake, Cassels & Graydon LLP
  • Article

    Transfer Pricing & APA Considerations During An Economic Disruption

    At times like this, when health and safety are at the forefront of everyone's mind, tax planning, including transfer pricing, understandably, is generally put aside.
    CanadaTax
    Gowling WLG
    Gowling WLG
  • Article

    Tax Considerations For Foreign Investors – Financing Acquisitions In Canada

    Cross-border investments often provide opportunities to shift tax deductions and income between jurisdictions in order to maximize global tax efficiency.
    CanadaCorporate/Commercial Law
    Stikeman Elliott LLP
    Stikeman Elliott LLP
  • Article

    Cross-Border Tax: How Trump's 'One Big Beautiful Bill' (OBBB) Will Affect Canadians With American Income, Investments, Business Operations

    The U.S. recently enacted the One Big Beautiful Bill (OBBB), a major tax reform affecting individuals and corporations. While primarily U.S.-focused, the legislation has important consequences for Canadians with U.S. income, investments, or business operations.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Ontario’s New Civil Liability Regime: Implications For Investment Funds

    The recently-proclaimed amendments to the Ontario Securities Act that create causes of action for investors in the secondary market with respect to misleading, insufficient or late disclosure will become effective on December 31, 2005. This update considers how the new regime will affect mutual funds and other investment funds that are reporting issuers.
    CanadaFinance and Banking
    Osler, Hoskin & Harcourt LLP
    Osler, Hoskin & Harcourt LLP
  • Article

    Case Comment: BNY Capital Corp. V. Katotakis

    This is a case comment on the Ontario Court of Appeal’s February 23, 2005 decision in BNY Capital Corp v. Katotakis (2005), 1 B.L.R. (4th) 168
    CanadaLitigation, Mediation & Arbitration
    Borden Ladner Gervais LLP
    Borden Ladner Gervais LLP
  • Article

    2016 Federal Budget: Cross-Border Impact

    The new Liberal government's first budget included a number of cross-border measures impacting transfer pricing documentation, the arm's length principle for transfer pricing...
    CanadaTax
    Grant Thornton
    Grant Thornton
  • Article

    Changes Coming To Country-By-Country Transfer Pricing Documentation Requirements

    Businesses with international operations need to be aware of changes to the required transfer pricing documentation that will apply in the near future.
    CanadaTax
    Gowling WLG
    Gowling WLG
  • Article

    Navigating Cross-Border Tax Challenges

    In this exclusive interview with CanadianSME Small Business Magazine, we connect with Errol Tenenbaum, Partner at Robins Appleby LLP, specializing in Tax, Estate Planning, and Business Law, alongside Jordana Lyons...
    CanadaTax
    Robins Appleby LLP
    Robins Appleby LLP
  • Article

    SCC Clarifies Jurisdictional Issue In Canadian Tax Disputes: Iris Technologies And Dow Chemicals

    On June 28, 2024, the Supreme Court of Canada (SCC) released Dow Chemical Canada ULC (2024 SCC 23) (Dow) and Iris Technologies Inc. (2024 SCC 24) (Iris), two decisions which sought to clarify whether...
    CanadaTax
    Cassels
    Cassels
  • Article

    Bill C-15 Receives Royal Assent: What It Means For Canada’s Transfer Pricing Rules

    On March 26, 2026, Bill C-15 (Budget 2025 Implementation Act, No. 1) received Royal Assent, bringing into force significant amendments to Canada’s transfer pricing rules under section 247 of the Income Tax Act.
    CanadaTax
    Borden Ladner Gervais LLP
    Borden Ladner Gervais LLP
  • Article

    Canada's Federal Budget 2021 And International Trade Implications

    On April 19, 2021, the Federal Government of Canada unveiled its first budget in two years, promising over $100 billion in new spending intended to propel Canada's economic recovery from the COVID-19 pandemic.
    CanadaInternational Law
    Bennett Jones LLP
    Bennett Jones LLP
  • Article

    Business Measures In 2019 Federal Budget

    The 2019 Canadian federal budget was released on March 19, 2019.
    CanadaTax
    Bennett Jones LLP
    Bennett Jones LLP
  • Article

    Canada’s Supreme Court Releases First Transfer Pricing Decision In GlaxoSmithKline

    In a unanimous decision, released on October 18, 2012, the Supreme Court of Canada upheld the judgment of the Federal Court of Appeal in "Canada v. GlaxoSmithKline Inc."
    CanadaTax
    Osler, Hoskin & Harcourt LLP
    Osler, Hoskin & Harcourt LLP
  • Article

    Canadian Tax @ Gowlings

    This article relates to recent developments in Canadian Tax Law.
    CanadaTax
    Gowling WLG
    Gowling WLG
  • Article

    Government Of Canada Tests The Limits Under The Income Tax Act In 2017

    In 2017, the Canada Revenue Agency (the CRA) pursued litigation which tested the limits of its powers under the Income Tax Act.
    CanadaTax
    Osler, Hoskin & Harcourt LLP
    Osler, Hoskin & Harcourt LLP
  • Showing 141–160 of 393 results

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