Jean Marc Gagnon and Emmanuel Sala, of Blake, Cassels & Graydon, examine how the Tax Court of Canada’s decision to let the Canada Revenue Agency (CRA) introduce new transactions as evidence on the eve of a transfer pricing trial extends the CRA’s right to advance alternative arguments supporting an assessment.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
While the IBS incorporates taxable events previously covered by state and municipal taxes, its governance and operational logic represent a significant departure from the legacy model
MNEs now face a shift from modelling to execution as the side‑by‑side deal forces tax teams to upgrade systems, harmonise data, and prevent costly pillar two mismatches
Almost three-quarters of surveyed tax professionals are concerned about inaccurate AI outputs; in other news, Dentons hired a partner from CMS to lead its Belgian tax team
Brazil’s shift to a nationwide consumption tax is more than conceptual; it fundamentally transforms municipal revenue, enforcement, and administrative disputes