The United States has so far put in place 11 bilateral competent authority arrangements for the automatic exchange of country-by-country reports, the OECD reported a June 22 release. The US now has . . .
Eight countries are working on a new program to jointly review large multinationals’ tax affairs and, if appropriate, provide assurances to the multinational that it will not likely be audited in those jurisdictions with respect to specific tax risks, officials said June 6 in Washington at a conference sponsored by the OECD, USCIB, . . .
Canada’s Federal budget 2017, released today, proposes to amend the Income Tax Act to prevent income from the insurance of Canadian risks from being shifted to a foreign branch of a Canadian life insurer . . .
The OECD has today asked international business to report grievances about the mutual agreement procedure (MAP) for resolving cross-border tax disputes in the US, UK, Belgium, Canada, Netherlands, and Switzerland. The OECD seeks responses to a . . .
Goodmans LLP tax attorney, Kabir Jamal, provides an analysis of the international tax proposals in the Canadian government’s draft tax bill, issued July 29, including measures that address foreign exchange gains on foreign-currency debt, back-to-back loan and royalty arrangements, and country-by-country reporting . . . .
Carrie Smit, a partner with Goodmans LLP, Toronto, analyzes the Canadian Federal Court of Appeals March 4 decision in The TDL Group Co. v. The Queen, which concluded that a Canadian company is entitled to deduct interest on an intercompany loan used to acquire shares of its US subsidiary. . .
Kabir Jamal, an attorney with Goodmans LLP, Toronto, discusses statements made by Canadian Revenue Agency officials at a conference last week announcing the agency’s decision to classify Florida and Delaware LLPs and LLLPs as corporations for income tax purposes . . .
Officials from six countries today signed a multilateral agreement that sets out the parameters for the automatic exchange of country-by-country reports on large multinational corporations. China, India, Canada, Iceland, Israel, and New Zealand joined 33 other countries that have . . .