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Kaitlin Gray

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Osler Update Jul 2, 2024

Dow Chemical and Iris Technologies: Supreme Court rules on jurisdictional issues in tax matters

In this Update: On June 28, 2024, the Supreme Court released its decisions in Dow Chemical and Iris Technologies regarding the respective...

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Dow Chemical and Iris Technologies: Supreme Court rules on jurisdictional issues in tax matters
Osler Update May 2, 2024

Canadian government moves ahead with Global Minimum Tax Act

Canada’s Pillar Two legislation, the Global Minimum Tax Act, is introduced in Parliament. In their Update, Patrick Marley, Oleg Chayka, Ilana...

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Canadian government moves ahead with Global Minimum Tax Act
Osler Update Apr 30, 2024

Transfer Pricing 2024: Law and Practice

The federal government has plans to update the rules that govern transfer pricing — the pricing one branch or division or group of a company...

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Transfer Pricing 2024: Law and Practice
Osler Update Feb 28, 2024

CRA releases revised APA guidance

The CRA revised its guidance on Advance Pricing Arrangements, introducing significant updates to criteria for acceptance into the program. The...

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CRA releases revised APA guidance
Osler Update Dec 11, 2023

Transfer pricing proposals infuse Canada’s tax laws with OECD concepts

Canada’s transfer pricing rules ensure that, for Canadian income tax purposes, the pricing of non-arm’s length cross-border transactions adheres...

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Transfer pricing proposals infuse Canada’s tax laws with OECD concepts
Osler Update Aug 10, 2023

Draft Canadian Pillar Two global minimum tax legislation and revised DST legislation

The Department of Finance released draft legislation implementing two key measures of the OECD’s Pillar Two global minimum tax in Canada: the...

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Draft Canadian Pillar Two global minimum tax legislation and revised DST legislation
Osler Update Aug 9, 2023

Finance proposes tying transfer-pricing rules to OECD guidelines

An article by Kaitlin Gray discusses Finance’s consultation paper proposing to rewrite Canada’s transfer pricing rules.

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Osler Update Jun 12, 2023

Department of Finance releases consultation paper proposing amendments to Canada’s transfer pricing regime

On June 6, the Canadian Department of Finance released a consultation paper proposing amendments to Canada’s transfer pricing regime and opened a...

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Osler Update Feb 7, 2023

OECD releases guidance for Pillar Two, including GILTI coexistence and QDMTT design

The OECD released administrative guidance for implementing the global minimum tax under Pillar Two, including GILTI coexistence and QDMTT design.

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Osler Update Aug 10, 2021

TPM-02R: Transfer-Pricing Secondary Adjustments and Repatriation

TPM-02R replaces Transfer Pricing Memorandum TPM-02, “Repatriation of Funds by Non-Residents—Part XIII Assessments,” and certain paragraphs...

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