Transfer Pricing Newsletter

Sep 27, 2017

Eaton A.P.A. cancellations were an abuse of I.R.S. discretion

This article appears in Insights vol. 4, Issue 9.  Insights… Read more »

May 29, 2017

Amazon makes the CUT – an important taxpayer win, a reminder to consider transactional evidence

This article also appears in the May issue of Insights,… Read more »

Dec 15, 2016

Is the CRA skipping dinner in the hope of getting its deserts? Digesting the “new” Canadian transfer pricing documentation standard

The CRA was recently asked “Will the CRA’s expectations of… Read more »

Sep 20, 2016

A new way to do the splits: BEPS draft guidance falls short of enabling global formulary apportionment

This article also appears in INSIGHTS vol 3 no 7… Read more »

Jun 17, 2016

Mind the $2 billion gap – Medtronic decision for the taxpayer favors pricing transactions over profit split

The U.S. Tax Court recently decided for the taxpayer in… Read more »

Apr 08, 2016

Canadian transfer pricing rules – scattered from far and wide

The recent March 22 budget announced an update of the… Read more »

Mar 07, 2016

Is the CUP half empty?

In its recent decision in Marzen Artistic Aluminum Ltd. [2016… Read more »

Oct 19, 2015

New transfer pricing guidance from the OECD – A Hitchhiker’s Transfer Pricing Guidelines to the Galaxy

The October 5, 2015 releases from the controversial OECD/G20 BEPS… Read more »

Sep 29, 2015

Making popcorn from a kernel of truth – Does the U.S. Tax Court decision in Altera have broader consequences?

The U.S. Tax Court’s recent decision in Altera v. Comr…. Read more »

Jul 09, 2015

Rowing with only one ‘or’ in the water, as the interpretation of section 247(2) remains unclear

On June 12, the Federal Court of Appeal issued its… Read more »

Jun 15, 2015

A proposed treatment for HTVI

If you or your clients suffer from HTVI, or ‘hard… Read more »

May 22, 2015

Taxing the returns to intangible assets – will tax authorities know ‘value creation’ when they see it?

One hallmark of good guidance is clarity of terms and… Read more »

Yes, Virginia, there is a Santa Claus – BEPS Action 11 is still searching for quantification of corporate income tax lost to BEPS

Of all the actions in the G20 and OECD Base… Read more »

Mar 17, 2015

Transfer Pricing Litigation from A to Z

A number of transfer pricing cases, many with potentially significant… Read more »

Dec 12, 2014

Holiday shopping, Canadian retail prices and transfer pricing controversy

If you grew up near the Canada-U.S. border, you may… Read more »

Nov 10, 2014

Free In The Harbour? Draft guidance on transfer pricing for low value-adding services released by the OECD

As part of its work on Action 10 of the… Read more »

Aug 11, 2014

Should a company have a transfer pricing agreement?

‘Transfer pricing agreement’ is sometimes the way a company owner… Read more »

Jun 20, 2014

‘California Dreamin’ for only $32,500 per year* (*Part I and Part VIII tax, interest, and transfer pricing penalties not included)

Until June 10, companies could only make an educated guess… Read more »

May 13, 2014

A transfer pricing lesson from McKesson?

In late 2013, the Tax Court of Canada released its… Read more »

Apr 15, 2014

IRS vs. OECD — how are tax authorities planning to conduct your next transfer pricing audit?

Over the past 15 months, the IRS and the OECD… Read more »

Feb 10, 2014

Country-by-Country reporting goes the Full Monty: not good news for international businesses

The Organisation for Economic Cooperation and Development (OECD) published adiscussion… Read more »