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  • Phil Fortier, Alex Evans, and Raf Sattar of Deloitte in Canada summarise the key aspects of Canada’s APA programme report for 2017, allowing taxpayers and tax practitioners to align expectations of the scheme with the current approach.
  • The US Tax Court will have to once again review whether Medtronic’s use of the comparable uncontrolled transactions (CUT) method complied with regulations after the Eighth Circuit Court referred the case back for deeper analysis.
  • Michito Kitamura
  • Henry An
  • Chinawat Assavapokee
  • Robert Chen
  • Suresh Perera
  • Current trends suggest that multinational organisations will continue to spend more time and resources managing tax controversies in both their local and foreign markets. Tax authorities are sharing information about companies and focusing increasingly not just on the technical merit of a tax position but also on implementation.
  • Stef van Weeghel
  • Ulf Andresen