Brad Rolph of Charles River Associates in Canada takes a closer look at the memorandum of understanding (MOU) on arbitration between the US and Canada and the accompanying arbitration board operating guidelines. He also examines whether the arbitration procedure is accomplishing its objectives to reduce the amount of time it takes to resolve double taxation cases and increase the use of principle-based negotiating positions.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
A landmark ruling on LLP taxation has clarified who truly holds ‘significant influence’ and which partnership structures are most likely to withstand HMRC scrutiny
Fresh from the UN negotiations in New York, Alex Cobham offers ITR readers a rare first-hand perspective on the future of international tax cooperation
Despite initial hopes that the reporting obligation had been suspended, compliance challenges brought by Brazil’s indirect tax reform are very much a reality