Tax Disputes

CRA’s power to audit and assess: new developments, old problems

Proposed statutory amendments grant the Canada Revenue Agency more discretionary power.

Dow Chemical and Iris Technologies: Supreme Court rules on jurisdictional issues in tax matters

In this Update: On June 28, 2024, the Supreme Court released its decisions in Dow Chemical and Iris Technologies regarding the respective...

Major Canadian tax bills enacted into law

Two major Canadian tax bills were enacted into law before Parliament adjourned for the summer. The Fall Economic Statement Implementation Act, 2023...

Canadian government moves ahead with Global Minimum Tax Act

Canada’s Pillar Two legislation, the Global Minimum Tax Act, is introduced in Parliament. In their Update, Patrick Marley, Oleg Chayka, Ilana...

Federal budget briefing 2024

Get expert insight and analysis of the tax proposals in Budget 2024, including the capital gains inclusion rate increase and other new or updated...

Department of Finance releases consultation papers on patent box regime and SR&ED

The Department of Finance opened two consultations regarding a new patent box regime and the existing SR&ED program with comments due by April 15.

OECD releases transfer pricing guidance on a simplified and streamlined approach (Amount B of Pillar One)

The OECD has released its first transfer pricing report on Amount B of Pillar One, which introduces a simplified transfer pricing methodology for...

OECD releases third administrative guidance on Pillar Two and confirms delay of the Pillar One timeline

The OECD has published the third administrative guidance on Pillar Two and has confirmed the delay of the Pillar One timeline.

Implementation bill for variety of Canadian tax measures introduced

The Canadian government introduced an implementation bill and related explanatory notes on November 30, 2023, for several tax measures, including the...

Osler submission on Canada’s draft Global Minimum Tax Act

On August 4, 2023, the Department of Finance released draft legislation implementing two key measures of the OECD’s Pillar Two global minimum tax...