After years of maintaining a reactionary stance, the Canada Revenue Agency (CRA) and the Canadian Department of Justice (DOJ) have collectively refocused their efforts to move earlier and more aggressively, thereby redrawing the battle lines as to the manner in which tax disputes are fought. Brandon Siegal and Chia-yi Chua of McCarthy Tétrault explain how to avoid the cross-hairs of the country’s tax officials.
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India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist
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