Ilana Ludwin

OECD releases model rules for global minimum tax

The OECD released model rules for the proposed global minimum tax under Pillar Two of the OECD/G20 Inclusive Framework.

Economic and Fiscal Update 2021

The 2021 Economic and Fiscal Update sets out measures adopted and proposed to address the pandemic and support Canada’s economic recovery.

Tax planning developments: Important international tax changes

In 2021, a number of significant changes were proposed for international taxation in Canada. Find out more about what changes were introduce in 2021...

Supreme Court releases Alta Energy decision: taxpayer wins, application of GAAR to tax treaties clarified

Earlier today, the Supreme Court of Canada released its decision in Canada v. Alta Energy Luxembourg S.A.R.L., 2021 SCC 49.

Updated Canadian administrative guidance on competent authority assistance

The Canada Revenue Agency (CRA) released its first update in 16 years to its administrative guidance on seeking assistance from the Canadian...

COVID-19 tax measures and proposed international tax reform

Two significant tax developments in 2020 were Canada’s measures in response to COVID-19 and Canada’s participation with the OECD’s pursuit of...

Supreme Court of Canada clarifies the remedy of rectification in Canadian tax cases

On December 9, 2016, the Supreme Court of Canada released two much-awaited decisions in Fairmont and in PJC that clarified the scope of the remedy...

Applying the TPSM in Canada

The discussion draft on the application of the Transactional Profit Split Method (TPSM) presents the TPSM as a multi-sided transfer pricing method.