Searching Content indexed under Transfer Pricing by Osler, Hoskin & Harcourt LLP ordered by Published Date Descending.
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Impact Of Recent International Tax Developments On Canada
Recent international tax changes proposed by the OECD could significantly impact the cross-border activities of Canadians – particularly with respect to tax planning strategies that shift profits to low or no-tax jurisdictions.
5 Jul 2019
Federal Court Of Appeal Holds Canada Revenue Agency Does Not Have The Power To Compel Oral Interviews During Audit
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,
17 Apr 2019
Osler Submission To OECD On Public Consultation Document Addressing The Tax Challenges Of The Digitalisation Of The Economy
Osler made a submission [PDF] to the OECD in response to its February 13, 2019 public consultation document on the possible solutions to the tax challenges of digitalization (the 2019 Public Consultation Document).
18 Mar 2019
From Transfer Pricing To Tax Treaties: Canadian Cross-Border Tax Update
The two most significant Canadian cross-border tax developments in 2018 relate to transfer pricing and tax treaties.
27 Dec 2018
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.
3 Jan 2018
New PPT Rule In The OECD's Multilateral Instrument To Displace Canadian GAAR?
On June 7, 2017, Canada signed the OECD's Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI)...
29 Nov 2017
U.S. Tax Reform For Busy Canadians (Part 2 – Senate Update)
One week after the House released its draft tax bill, the U.S. Senate Finance Committee released a 253-page summary of its tax reform proposals (the Senate Summary) on November 9....
21 Nov 2017
U.S. Tax Reform For Busy Canadians
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...
13 Nov 2017
Federal Court Of Appeal's Univar Decision Provides Guidance On How To Apply The GAAR
On October 13, 2017, the Federal Court of Appeal released its highly anticipated decision in Univar, finding that the General Anti-Avoidance Rule (GAAR)...
1 Nov 2017
OECD Releases 2014 BEPS Deliverables
OECD released its first seven of 15 deliverables under the OECD/G20 base erosion and profit shifting (BEPS) project (the 2014 BEPS Package).
18 Sep 2014
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."
23 Oct 2012
Recent U.S Transfer Pricing Decisions Viewed as Favourable to Taxpayers
On December 10, 2009, the United States Tax Court rejected the position taken in an Internal Revenue Service (IRS) deficiency notice in the transfer pricing area in a decision that has been viewed as favourable to taxpayers
24 May 2010
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.
19 Oct 2005
New NI 45-106 Introduces Important Changes To Québec Private Placement Framework
Effective September 14, 2005, National Instrument 45-106 – Prospectus and Registration Exemptions (NI 45-106), adopted by way of regulation, introduces important changes to the Québec securities regulatory framework effectively replacing the prospectus and registration exemptions previously contained in the Securities Act (Quebec) (the Act) with a nationally harmonized set of exemptions that, for the most part, mirrors the regime currently in force in Ontario.
19 Oct 2005
Federal Lobbyists Registration Act Amendments to Come Into Force on June 20, 2005
With the regulations to the Act now finalized, this date will start the clock running on filing requirements for both consultant lobbyists and corporations or organizations that employ in-house lobbyists. Here, we provide an overview of transitional filing requirements and other key provisions.
17 Jun 2005
Canadian Transfer Pricing Developments Multinationals Should Know About
Prompted by government concerns about the depletion of Canada’s tax base, tax authorities here are now using transfer pricing principles as a primary audit tool to evaluate – and challenge – income allocation to Canada by multinationals. As a result, virtually all cross-border business activities between related parties are now subject to transfer pricing audits. Here, we look at some of the key areas tax authorities are zeroing in on.
16 Jul 2004
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