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May 02, 2013
Deborah Toaze, of Blake, Cassels & Graydon, looks at what a Federal Court (Canada) (FC) ruling means for the Canada Revenue Agency’s (CRA) ability to obtain foreign-based information from taxpayers.
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April 04, 2013
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.
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March 13, 2013
Some non-Canadian resident businesses may be entitled to refunds for GST/HST paid in error on purchases from Canadian suppliers, says John Bain of KPMG.
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March 06, 2013
Scott Wilkie and Janice McCart, of Blake, Cassels & Graydon, believe the continuing examination by bodies such as the OECD of how international tax rules operate means that tax reporting by Canadian taxpayers should be as thorough as possible.
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February 07, 2013
Scott Wilkie and Janice McCart, of Blake, Cassels & Graydon, explain how multinationals can prepare for risk-based assessments in Canada and abroad by proving the terms of related-party contracts match the substance of their relationships with those entities.
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January 09, 2013
Deborah Toaze and Barbara Mazur of Blake, Cassels & Graydon update taxpayers on the Canada Revenue Agency’s (CRA) latest transfer pricing policies.
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May 22, 2013
In the third of his four-part series for International Tax Review, Donald Bowman QC, former Chief Justice of the Tax Court of Canada, now counsel to Dentons’ national tax group, discusses the increased use of expert testimony in disputes involving tax treaty interpretation.
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May 20, 2013
International Tax Review has produced tax disputes reference guides for 26 countries. The guides look at how multinationals can avoid and manage tax disputes in each jurisdiction as well as offering insight about the future litigation strategies of individual tax authorities.
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May 13, 2013
In the second of his four-part series for International Tax Review, Donald Bowman QC, former Chief Justice of the Tax Court of Canada, now counsel to Dentons’ national tax group, examines the use of expert witnesses in transfer pricing cases and in giving valuation opinions.
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May 10, 2013
In a ruling handed down May 6, 2013, Canada's Federal Court of Appeal ordered that portions of a Crown pleading be struck out on Monday for suggesting that a tax deduction may be disallowed on the basis that the conduct of the taxpayer in incurring the expense was egregious or repulsive.
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May 09, 2013
Donald Bowman QC, former Chief Justice of the Tax Court of Canada, now counsel to Dentons' national tax group, discusses how taxpayers and their counsel can most effectively use expert witnesses in a Tax Court trial.
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May 02, 2013
Deborah Toaze, of Blake, Cassels & Graydon, looks at what a Federal Court (Canada) (FC) ruling means for the Canada Revenue Agency’s (CRA) ability to obtain foreign-based information from taxpayers.
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April 04, 2013
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.
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April 03, 2013
More Canadian companies are being told that they may owe GST plus penalty interest on reinsurance premiums paid to non-resident related-parties dating back eight years. This is a result of increased auditing activity around reinsurance by the Canada Revenue Agency (CRA).
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April 02, 2013
Last week’s publication of Finance Bill 2013 confirmed the UK is to introduce a General Anti-Abuse Rule (GAAR) later this year. But there is no consensus that the proposed measure is necessary or that it will be effective. One criticism is that legislators have not taken on board the lessons learnt in other jurisdictions such as Australia, Canada, New Zealand and South Africa.
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March 28, 2013
The Canada Revenue Agency will be encouraged to increase its use of information gathering powers granted to it under the Canadian Income Tax Act during transfer pricing audits, after the Federal Court allowed its foreign-based information request to examine footwear retailer Soft-Moc’s tax affairs last week.
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March 27, 2013
The Canadian government has imposed extra information reporting requirements on certain financial institutions and raised the possibility of rewards for information about international tax non-compliance.
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March 27, 2013
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March 26, 2013
Canada’s 2013 federal budget (Budget 2013) was released on March 21 2013 and focused on spending in support of job creation and on tightening a number of tax measures. It also included a number of significant developments from a cross-border perspective that are highlighted here.
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March 20, 2013
Oregon has expressed interest in British Columbia’s carbon tax, but a European-style carbon market for North America is not on the cards, say advisers.
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March 13, 2013
Some non-Canadian resident businesses may be entitled to refunds for GST/HST paid in error on purchases from Canadian suppliers, says John Bain of KPMG.
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March 06, 2013
Scott Wilkie and Janice McCart, of Blake, Cassels & Graydon, believe the continuing examination by bodies such as the OECD of how international tax rules operate means that tax reporting by Canadian taxpayers should be as thorough as possible.
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February 13, 2013
The Canada Revenue Agency (CRA) must disclose to taxpayers how specific provisions of the Income Tax Act (Act) were abused whenever it applies the general anti-avoidance rule (GAAR) in a dispute, the Tax Court of Canada has ruled. And advisers say taxpayers could benefit from this information in future GAAR cases.
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February 07, 2013
Scott Wilkie and Janice McCart, of Blake, Cassels & Graydon, explain how multinationals can prepare for risk-based assessments in Canada and abroad by proving the terms of related-party contracts match the substance of their relationships with those entities.
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January 31, 2013
The Canada Revenue Agency (CRA) has revealed how it will identify high-risk taxpayers as audit targets in its response to questions posed by the Tax Executives Institute (TEI) which was published today. And the tax authority said there will be no scope for companies to negotiate better risk ratings once they have been determined.
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January 29, 2013
David Penney, head of tax for General Motors in Canada, is one of six new members of the Internal Revenue Service Advisory Council (IRSAC) in the US.
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January 09, 2013
Deborah Toaze and Barbara Mazur of Blake, Cassels & Graydon update taxpayers on the Canada Revenue Agency’s (CRA) latest transfer pricing policies.
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September 12, 2011
Tax Controversy Leaders is a guide to the leading tax dispute resolution lawyers and advisers in the world. In addition to highlighting tax professionals, the guide also includes litigators and barristers who may not practise tax on a day to day basis.
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October 26, 2012
Scott Wilkie, one of the most recognised names in the Canadian tax market, has joined Blake, Cassels & Graydon as a partner in the firm's Toronto office.
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May 11, 2012
Serge Gloutnay has joined Gowlings – Taxand Canada in Montreal as a partner in its Montréal office.
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January 10, 2012