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Canada and other members of the OECD and the G-20 are engaged in a project to address "base erosion and profit shifting" strategies used by multinational enterprises.

On August 29, 2014, the Minister of Finance released for consultation draft legislative proposals to amend the Income Tax Act (Canada).

The Minister of Finance delivered the 2012 Canadian federal budget on March 29, 2012.

Administrative tax penalties have become one of the Canada Revenue Agency's (CRA) most powerful enforcement tools.

On October 5, the OECD presented its final package of measures attacking base erosion and profit shifting.

The release of H.R. 1, or the Tax Cuts and Jobs Act [PDF], by the U.S. House Committee on Ways and Means on November 2 marks the beginning of what will surely be a raucous and frantic push...

The growth in international business has led to more Canadian companies transacting across borders with related parties, making transfer pricing an important focus of the CRA.

On June 10, 2014, the Tax Court of Canada delivered its most recent decision on transfer pricing, one which involved a Barbados structure.

On March 22, 2016 ("Budget Day"), Minister of Finance Morneau of the recently-elected Liberal Government tabled his first federal budget ("Budget 2016")...

This case involved a landmark transfer pricing dispute in which the Canada Revenue Agency (the "CRA") reassessed the taxpayer for additional income of CAD$483,431,713 for the years 2003-2006 ...

On June 23, two senior Canada Revenue Agency ("CRA") officials outlined a status update on tax controversy and dispute resolution at this stage of the COVID-19 pandemic.

The OECD released the BEPS Action Plan in response to concerns that multinational enterprises were artificially reducing taxable income.

Canadian taxpayers who engage in cross-border dealings with related non-residents face special reporting requirements. One of the most important filings in this area is CRA Form T106, Information Return of Non-Arm's Length Transactions with Non-Residents.

In Canada v. GlaxoSmithKline Inc., the Supreme Court of Canada succinctly summarized transfer pricing and the tax concerns surrounding it.

For months, there has been widespread speculation as to the measures that Budget 2021 would introduce, given that it has been more than two years since the last federal budget and the ...

In Part I of this article,[1] we provided an overview of transfer pricing developments in Canada since the start of the Organization for Economic Cooperation and Development's

The Kyoto Protocol to the United Nations Framework Convention on Climate Change (the "Protocol Protocol") entered into force on February 16, 2005 and committed thirty industrialized countries to reduce or limit their greenhouse gas ("GHG GHG") emissions for the period between 2008 and 2012. Under this new treaty, Canada has committed to a reduction of 6% below 1990 levels – a reduction which translates into a so-called "Kyoto Gap" of 270,000,000 tonnes of carbon dioxide equivalent or 270 Mt pe

With the tabling of its federal Budget ("Budget 2019"), the Federal Government (the "Government") has renewed its commitment to "investing" in the Canadian middle class