Aug. 25, 2020 - The federal government passed legislation on July 27, 2020, extending the Canada Emergency Wage Subsidy (CEWS) and significantly broadening its reach. In this guide, we provide a comprehensive review and analysis of the CEWS program, including details of the latest updates and key considerations...
Canadian Transfer Pricing Decision in Marzen: Points of Interest
In this article from Tax Notes International, Davies partner Nathan Boidman reviews Marzen Artistic Aluminum, a Canadian transfer pricing case involving sales of Canadian products into U.S. markets. Nathan focuses on novel issues raised by the parties’ use of a Barbados subsidiary in the operating structure and the separate question of the decision’s possible effects on the implementation in Canada of any of the action 8-10 recommendations under the OECD’s base erosion and profit-shifting project.
Aug. 05, 2020 - The IRS recently released long-awaited final regulations (Final Regulations) on the limitation on the deductibility of interest expenses under section 163(j), along with new proposed regulations (New Proposed Regulations) that address a variety of highly technical issues that are not covered by...