Allan Lanthier examines a dispute before the Tax Court of Canada involving Brookfield Corporation and controlled foreign affiliates in Bermuda and Barbados

Allan Lanthier explains how some Canadian corporations have redomiciled to the United States and why there may be more to come unless changes are made

Section 1247, subsections 220(2.1) and 220(3), of the Income Tax Act can grant relief from tax reassessment and filing requirements, says David J Rotfleisch

Greg Farano of Gardiner Roberts LLP on the new MDRs, broad enough at first to apply to ordinary commercial and routine tax planning transactions

Michael Hunt and Steven Wenham of Herbert Smith Freehills LLP explain a transfer pricing ruling in the UK Supreme Court in favour of RBC and an oil exploration loan

Vern Krishna of TaxChambers LLP on the history of international tax and trade law

To delineate the limits to its new power, the Canada Revenue Agency should adopt these best practices for audit interviews, argue three tax lawyers from Davies

The multilateral plan for a global minimum corporate tax is too complex to work. The OECD should adopt minilateralism instead

Marc Pietro Allard and Marc André Gaudreau Duval of Davies on the implications of new excessive interest and financing expenses limitation rules

New trend of rising rates has already begun, says international accounting network

Allan Lanthier looks at the BVI Switch tax avoidance scheme used by wealthy Canadians and what action could be taken by the federal finance minister

In part two of his two-part series, Allan Lanthier highlights areas of the Supreme Court's Alta Energy decision that are open to vigorous debate

In part one of a two-part series, Allan Lanthier looks at the details of the Alta Energy tax avoidance decision by the Supreme Court of Canada

Professor Ronan Palan on the repercussions of the Pandora Papers

But legal argument just one obstacle towards implementation says Professor Rebecca Parry

Anticipate new accounting ways around the rules, says Professor Ronen Palan

Popping some media inaccuracies about the G7 two-pillar framework with Canadian tax lawyer and accountant David J Rotfleisch

Jared A. Mackey, Brendan Sigalet and Philip B. Ward of Bennett Jones LLP on a fundamental change to the existing interest deductibility regime

The gulf will continue to grow between Canadian tax law and OECD Transfer Pricing Guidelines, says Steve Suarez of Borden Ladner Gervais LLP

How the consequences of COVID-19 impact TP reporting and compliance is complex, say Claire M.C. Kennedy and Hennadiy Kutsenko of Bennett Jones

Will recent CRA tax court losses result in the toughening of transfer pricing rules?

Mark Kirkey of Gowling WLG on transfer pricing in the new economic reality

Be careful what you ask for, says John A. Sorensen of Gowling WLG