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Optimizing the opportunities for Indian companies in Canada should include planning to minimize income tax, customs duties, and value-added taxes.

On July 11, 2023, the OECD/G20 Inclusive Framework on BEPS approved a four-part Outcome Statement on the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation...

The OECD released its first Base Erosion and Profit Shifting recommendations to the OECD and G20 countries to combat tax avoidance by multinational enterprises.

Charging a royalty or licensing fee by one related party to another within a multinational setting for the use of valuable know-how, technology processes, trade names, or other intangible property, may be one of transfer pricing's most significant and contentious issues.

On April 7, 2020, the Internal Revenue Service (IRS) and U.S. Treasury Department released the final regulations and additional proposed regulations under the Tax Cuts and Jobs Act.

Canada's Phase 2 hybrid mismatch arrangement rules will deny deductions on a far broader set of cross-border payments starting July 1, 2026, particularly affecting structures with Canadian unlimited liability companies or partnerships treated as corporations for US tax purposes.

The Canadian tax landscape experienced significant developments this summer, from expanded CRA audit powers and AI-driven compliance to new transfer pricing rules and evolving trade tariffs. These five key updates carry important implications for taxpayers and multinational businesses as they navigate an increasingly complex regulatory environment heading into fall.

The Canada Border Services Agency has made some significant changes to its position on the treatment of downward price adjustments in value for duty calculations.

Revisions have been announced to the IRS’s relatively new program known as Pre-Filing Agreements, which provide potentially important benefits to foreign companies.

In The Bank of Nova Scotia v The Queen, the Tax Court of Canada (TCC) considered how to calculate arrears interest on an audit adjustment that is offset by a loss carryback.

Many Canadian businesses have closed the books on their 2020 fiscal year, having faced an unprecedented economic shock wrought by the pandemic.

Generally, transfer pricing studies rely on OECD tax principles; economists apply these principles with a focus on income tax outcomes.

On February 21, 2024, the Canada Revenue Agency (CRA) published a revised Information Circular (Circular) on the Advance Pricing Arrangement (APA) program.

The Canada Revenue Agency (CRA) has increasingly requested oral interviews during audits, particularly in transfer pricing audits. In Minister of National Revenue v. Cameco Corporation,

Wthout proper policies and documentation in place, transfer pricing audits can result in long and costly corporate headaches.

Earlier this month, we reported that a senior representative of the CRA had announced that it was "highly likely" that the incoming changes to the Voluntary Disclosures Program (VDP) ...

An often-quoted statistic is that only about 10 per cent of familyowned businesses remain sustainable into the third generation. This has a lot to do with the lack of proper planning while the founding...