Tax: M&A, Reorganizations and Restructuring Transactions Tax: M&A, Reorganizations and Restructuring Transactions

Applying the TPSM in Canada

The discussion draft on the application of the Transactional Profit Split Method (TPSM) presents the TPSM as a multi-sided transfer pricing method.

Budget Briefing 2016

A summary of the significant tax proposals included in Federal Budget 2016. Find out how these tax changes will affect Canadians and Canadian...

Taxpayer wins interest deductibility case at Federal Court of Appeal: The TDL Group Co. v. The Queen, 2016 FCA 67

The TDL Group Co. was denied an interest deduction based on borrowed money used to purchase common shares of a wholly-owned U.S. subsidiary.

U.S. Treasury Releases New Model Tax Treaty

The U.S. Treasury has released a revised model bilateral income tax treaty (the 2016 Model Treaty) which is a significant update to the 2006 model...

International Tax Reform 2015-BEPS Final Reports

Learn more about the BEPS final reports, now awaiting presentation and approval from G20 Finance Ministers. Now the attention turns to what extent...

U.S. Treasury Attempts to Influence OECD’S BEPS Initiative via Proposed Changes to U.S. Model Treaty

The United States has been criticized on more than one occasion for failing to be a meaningful participant in the OECD’s multi-pronged initiative...

Treaty Shopping – OECD Releases Revised Discussion Draft on BEPS Action 6

On May 22, 2015 the OECD released a revised discussion draft on “BEPS Action 6: Prevent Treaty Abuse” as part of its Action Plan on Base Erosion...

OECD Releases Proposed Changes to Permanent Establishment Rules

The OECD recently proposed recommendations for expanding the definition of “permanent establishment” in tax treaties.

OECD Discussion Draft Considers Controlled Foreign Corporation Rules

On April 3, 2015, the OECD released a discussion draft on Strengthening Controlled Foreign Corporation (CFC) Rules that stresses the importance of...

OECD Considers Availability of Tax Treaty Benefits for Investment Funds, Pension Funds and Private Equity Funds

On November 21, 2014, the OECD released a discussion draft that considers when tax treaty benefits should be granted to various investment funds,...