Topics to Discuss
- Introduction:
- Wheaton Precious Metals Cases
- Gagliese Case
- Landbouwbedrijf Case
- Kau Case
Wheaton Precious Metals Tax Cases
- The Canadian public company previously known as Silver Wheaton is in the business of providing financing to mining companies in return for a share of their production (a socalled "streaming company")
- The CRA audited Wheaton and its wholly‐owned Cayman subsidiary for the period 2010‐2015, and reassessed on the basis that Wheaton had violated the Transfer Pricing Rules
- As a result, the Cayman income of $715 million was attributed to the Canadian parent, which was assessed for $310 million of taxes, interest and penalties
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