Overview
Patrick Marley, Partner, Taxation, is co-chairing the 2014 Joint Canada–USA International Tax Seminar, to be held at the Hilton Toronto Hotel, under the auspices of the International Fiscal Association Canada. Patrick will be presenting opening remarks as well as moderating the session International Coordination (BEPS/Exchange of Information/FATCA). The presenters will provide an update on the BEPS action plan with a specific focus on typical Canada-U.S. structures and how they might be affected.
Richard Tremblay, Partner, Taxation, will be presenting at the session Transfer Pricing. The presenters will consider whether, if the U.S. or Canadian government were to endorse some of the transfer pricing approaches recently proposed in OECD documents related to BEPS, then the USA or Canada should, or would have to, make statutory or income tax treaty changes to implement these approaches or whether they could instead give legal effect to them administratively under existing statutes and treaties. The panel will also consider the legal and practical implications for transfer pricing of recent Canadian and USA developments.
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