The webinar deals with a variety of issues relevant to all multinational corporations. Topics covered include strategies to optimize global tax positions, as well as approaches to reduce exposure to unfavourable audits assessments resulting in double taxation. The speakers also discuss dispute resolution mechanisms that taxpayers can take advantage of to reduce or eliminate double taxation, including Competent Authority assistance and/or Appeals. Other topics covered include the impact of mandatory arbitration under the Canada US treaty (and its impact on resolving double taxation cases), permanent establishment issues involving wholly-owned subsidiaries and notional expense issues under the 5th Protocol, and changes to the Canadian Advanced Pricing Agreement program.
- Canada--Tax Court Rules on First Canadian Non-Discrimination Treaty Case
- Canada--Deemed Services PEs-Subcontractors vs. Agents-Canada Revenue Agency Adds Fuel to the Fire
- Current Developments Regarding Article XIII(8) of the Canada-U.S. Treaty From the Perspective of Dispositions of Taxable Canadian Property
- Canada Revenue Agency Provides Much-Needed Guidance by Issuing PE Ruling
- Canada-US Tax Treaty : Problems Impacting Canadian Employees Working in the US
- Transfer Pricing in Canada: Risk and Opportunities (PowerPoint)
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