The Osgoode Hall Law School Team - Miya Zakharchuk, Portia Biswas, Baiqing Luo, Daniel Mount, and Matt Wilson - were the winners yesterday of the 2021 Donald G. H. Bowman National Tax Moot. This is a remarkable, notable success for them and for the Osgoode community which they so ably represented. This Tax Moot […]
Monthly Archives: February 2021
The Cameco Transfer Pricing Appeal Ends Today
The Cameco Corporation transfer pricing decisions of the Tax Court of Canada and the Federal Court of Appeal are seminal, not just for Canadian taxation but internationally. The case wrestles with the interaction of private law constructions that lie at the heart of corporate and business organization, on the one hand, and the international […]
Transfer Pricing Conference Day 1 Highlight: Discussions on Recharacterization Rules
On Wednesday, February 3, 2021, the Canadian Tax Foundation hosted its Day 1 Program of the Transfer Pricing Conference virtually. Dialogues between the tax authorities and the private practice sector went back and forth on four panels. The highlight of the discussions was the recharacterization rules in paragraphs 247(2)(b) and (d) of the ITA. […]