Featured Cases

The European General Court Cuts Apple to Its Core: Reflections on Jurisdiction to Tax, Fiscal and Tax Sovereignty, and the Limits of Transfer Pricing

  The Apple Judgment[1] On July 15, 2020, the European General Court published its long-awaited judgment in the Apple “state aid” case.[2]  At issue is whether Ireland “aided” Apple by providing tax rulings limiting Irish tax to an agreed measure of the branch profits attributable only to activities in Ireland of two Apple subsidiaries that […]

Cameco: The Taxpayer Prevails in the Federal Court of Appeal and the Tax Court’s Decision is Sustained – But Conceivably Much More Than That

  Very shortly ago, the Federal Court of Appeal’s decision in The Queen v. Cameco Corporation (2020 FCA 112, delivered on June 26, 2020) was made public. By any measure in contemporary taxation (in Canada certainly, but for the transfer pricing world globally) the decisions of both the Tax Court of Canada and the Federal […]