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Results: 1-10 of 1,751

The Marzen decision: a typical example of BEPS
  • Gowling Lafleur Henderson LLP
  • Canada
  • October 7 2014

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


Clarifying the elements of, and defending against the offence of failure to comply with requirements for information
  • Thorsteinssons LLP
  • Canada
  • March 13 2015

Section 231.2(1) of the ITA (and s.289(1) ETA) gives the Minister a broad power to compel the disclosure of information or documents. In language


Canadian government urges Canadian court to reject challenge to FATCA agreement
  • Steptoe & Johnson LLP
  • Canada
  • November 14 2014

The Canadian government asked a Canadian court to uphold the intergovernmental agreement (IGA) entered into between Canada and the United States to


Judicial review application preserved in transfer pricing penalty case
  • Bennett Jones LLP
  • Canada
  • September 23 2014

A recent Federal Court of Appeal (FCA) case illustrates how contentious transfer pricing disputes can be - even one a taxpayer believed had been


Client update newsletter - fall 2014
  • WeirFoulds LLP
  • Canada
  • September 29 2014

The Supreme Court of Canada recently denied leave to appeal the Federal Court of Appeal’s (“FCA”) decision in Commissioner of Competition v. Toronto


Rectification: current developments regarding this useful judicial remedy
  • Miller Thomson LLP
  • Canada
  • July 31 2014

Rectification is an equitable remedy that allows for judicial corrections of a document that, due to errors in drafting, does not reflect the true


“Half-loaf” gone wrong: Gervais, G. et al. v. The Queen (“Gervais”).
  • Miller Thomson LLP
  • Canada
  • July 31 2014

A recent case from the Tax Court of Canada ruled against a taxpayer who implemented a tax plan known as the "half-loaf" plan. The purpose of a


U.K. Charity Commission decision in the Human Dignity Trust overturned implications of the decision
  • Miller Thomson LLP
  • Canada, United Kingdom
  • July 31 2014

A decision of the UK First-Tier Tribunal (Charity) has been released that will be of interest to charities in Canada, particularly those engaged in


Scope of GSA held to extend to GST input tax credits and related rights
  • Gowling Lafleur Henderson LLP
  • Canada
  • September 25 2014

A recent decision of the Tax Court of Canada highlights the benefits of a broadly drafted general security agreement (GSA) in relation to a secured


Communications with experts: Moore v. Getahun and the Advocates’ Society report
  • Dentons
  • Canada
  • July 17 2014

An expert does not draft hisher report in a vacuum. Communication with counsel is required. Ultimately, an expert must provide independent and