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North America focus

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  • Canada clarifies DFA and exchangeable share treatment

    Bill Maclagan, QC, partner at Blake, Cassels & Graydon, looks at the comments of the Canada Revenue Agency (CRA) on derivative forward agreements and exchangeable share transactions, and shares insights as to what the authorities are expecting from taxpayers.

  • Mexican Taxpayers’ Ombudsman – Mediator empowerment

    Mexico has incorporated an independent public organisation – Procuraduría de la Defensa del Contribuyente (PRODECON) – which acts as a taxpayers’ ombudsman, with a mandate to guarantee and protect the constitutional and human rights of taxpayers. René Meza and César De la Parra of Chevez, Ruiz, Zamarripa y Cía outline the salient features of the dispute resolution mechanisms under PRODECON.

  • Areas of TP scrutiny in a pre- and post-BEPS world

    Larissa Neumann, partner at Fenwick & West, assesses the transfer pricing landscape in the US, looking at authority attitudes and areas of focus based on recent dispute cases, and points to the need for consensus on the transfer pricing aspects of the OECD’s project to tackle base erosion and profit shifting.

International Correspondents