BEPS Cash Box Inconsistent with Canadian Tax Rules

Authors: Nathan Boidman and Michael N. Kandev

Originally published in Canadian Tax Highlights, this article examines the BEPS project’s new transfer-pricing notion of “cash box,” which appears to be inconsistent both with commercial reality and with longstanding Canadian outbound international tax policy.

Download this article.

Key Contacts



IRS Finalizes High-Tax Exception to GILTI

July 22, 2020 - The U.S. Treasury Department and the IRS have released final regulations (2020 Final Regulations) allowing certain domestic shareholders of a “controlled foreign corporation” (CFC) to elect under a high-tax exception to opt out of the tax imposed on the CFC’s “global intangible low-taxed...