This content is from: Taxpayers must prepare for onslaught of procedural disputes in Canadian courts Ed Kroft, QC, of Blake Cassels & Graydon discusses recent concerns of the Canadian courts about the increase in the number of procedural disputes in Canadian transfer pricing and tax avoidance cases. January 14 2011
This content is from: Canada Tax authorities lose appeal in GE Capital Canada case Canada’s Federal Court of Appeal (FCA) has dismissed the Crown’s appeal in the GE Capital Canada (GECC) transfer pricing dispute over the payment of a guarantee fee by a subsidiary to its parent. January 05 2011
This content is from: Canadian court rejects Crown’s appeal in case over guarantee fees The Federal Court of Canada (FCA) has confirmed a lower court decision holding that the payment of a taxpayer’s guarantee fee was in keeping with the arm’s length standard. January 03 2011
