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On July 26, 2010, the Canadian Federal Court of Appeal released its decision in the case of "GlaxoSmithKline Inc. v. Her Majesty The Queen".

Transactions entered into between a Canadian taxpayer or partnership and a non-arm’s length non-resident are generally subject to the transfer pricing rules contained in section 247 of the <I>Income Tax Act</I>.

On April 19, 2021, Canada's Deputy Prime Minister and Minister of Finance, Chrystia Freeland, released the first official budget in the past two years, titled, Federal Budget 2021...

The 2021 Federal Budget devoted an additional $304.1 million to the CRA to help it combat tax evasion and aggressive tax avoidance.

The Tax Court's mandate allows the DOJ and CRA to introduce new alternative theories late in litigation, which can increase cost, delay the litigation timeline, and introduce litigation fatigue.

The Supreme Court of Canada will release its decision in The Queen v. GlaxoSmithKline Inc. (F.C.) (33874) on Thursday, October 18, at 9:45 a.m.

The COVID-19 pandemic has made the lives of hundreds of millions of people around the world uncertain, wreaking havoc on all aspects of our daily lives

Canada continues to be the most important market for US franchisors operating outside of the US. The regulatory regime in Canada aimed specifically at franchising is much less developed and, accordingly, much less restrictive than in the US. Most franchised businesses involve retail restaurants, services, or sale of consumer goods, all of which usually rely heavily on their locations and the real estate related to those locations.

At the time Canada was amending its transfer pricing rules, much concern – and some confusion – arose over the potential application of the rules to financial transactions. This was particularly the case where the tax consequences of applying those rules to financial transactions were already regulated under other provisions of the Canadian Income Tax Act.

The Canada Revenue Agency recently took the unusual and unconventional step of notifying the tax community that it has settled a matter relating to a hybrid financing arrangement involving

The revised EIFEL rules remain open for consultation until January 6, 2023.

"The Order and Reasons for Recusal do not and should not form part of the record before this Court.

The Canada Border Services Agency (CBSA) has informed the Canadian importing community that importers may be entitled to obtain customs duty refunds in connection with downward transfer pricing adjustments.

On April 19, 2021, Deputy Prime Minister and Finance Minister Chrystia Freeland tabled in the House of Commons the Liberal Government's first federal budget in more than two years,

The Canadian Federal Court of Appeal recently overturned the Tax Court of Canada’s 2008 decision regarding the international transfer pricing of cross-border supplies of pharmaceutical ingredients in the case of GlaxoSmithKline Inc. v. Canada.

The OECD has recently released its Action Plan on Base Erosion and Profit Shifting.

Over the last few years, there has been an increase in the number of procedural disputes making their way through Canadian courts as part of the tax resolution process.