G7 finance ministers and central bank governors agreed at a meeting in Dresden held May 27–29 that the mechanisms used to settle tax disputes between nations need to be improved, German Finance Minister Wolfgang Schaeuble said. Schaeuble told a press conference following . . .
The Tax Court of Canada has concluded that TDL Group, a Canadian subsidiary of Wendy’s International Inc., the US restaurant chain, may not deduct $10 million (7.8 million USD) interest on loans from its parent in 2002. TDL used the loan to acquire additional shares of its wholly owned US subsidiary, Tim Donut US Limited, Inc., which then lent
Professor Allison Christians of McGill University provides an update of the lawsuit. See: Tax, Society & Culture. Related: MNE Tax.
International tax provisions in the Canadian government’s budget 2015, released April 21, provide withholding tax relief to non-resident employers whose employees work in Canada for short periods of time and tighten an antiavoidance rule applicable to captive insurance . . .
Canada’s Department of Finance has released proposed international tax legislation, including measures to implement the government’s 2014 budget, but said it decided to postpone action on anti-treaty shopping legislation.
The proposals, released on August 29, include amendments to Canada’s foreign affiliate dumping rules . . .
More analysis: KPMG
McKesson Corp., which is appealing an adverse decision in a transfer pricing dispute in Canada’s Federal Court of Appeal, filed a motion to amend its appeal on November 3 claiming that actions taken by the trial judge in filing a lengthy “Reasons for Recusal,” gave McKesson additional grounds for appeal, writes Timothy Fitzsimmons of Dentons in a . . .
The Canadian government on January 7 announced that launch of the Canada Revenue Agency’s (CRA) Electronic Funds Transfer (EFT) initiative, which effective January 1, requires financial intermediaries, including banks, to report to the CRA incoming and outgoing international EFTs of $10,000 or more. The. . .
Canada signed 31 advanced pricing arrangements (APAs) in FY 2014/2015, the most in five years, according to data released August 20 by the Canadian Revenue Agency (CRA). A total of 29 bilateral and 2 unilateral . . .
The Canadian Revenue Agency (CRA) has issued guidance on the use of multiple year data in determining the arm’s length price in transfer pricing cases. The guidance also address the use of statistical tools . . .
Two Canadian-U.S. dual citizens, on August 11, filed suit in the Federal Court of Canada challenging the constitutionality of the intergovernmental agreement signed by the U.S. and Canada that implements FATCA.
The lawsuit, funded by the Alliance for the Defense of Canadian Sovereignty (ADCS), alleges that the intergovernmental agreement violates provisions of the Canadian Charter of Rights and Freedoms . . .
G7 leaders, in a joint declaration issued June 8, made a “commitment to establish binding mandatory arbitration to ensure that the risk of double taxation does not act as a barrier to cross-border trade and investment.” The leaders also said they support work being done on binding arbitration as part of the OECD/G20 base erosion profit shifting (BEPS) project, and encouraged others . . .
UPDATE (6/9/2015): Christian Aid sounds alarm over G7 plan for mandatory tax arbitration: Christian Aid, on June 9, called the G7 leaders’ expression of support for compulsory binding arbitration in multinational tax disputes “deeply troubling,” stating . . .
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