The U.S. corporate tax rate is now 21% (down from 35%) along with other important changes. Companies should meet with their tax and transfer pricing advisors for specific advice on their U.S. operations.
IRS Update
The IRS launch campaign to audit U.S. distributors that buy goods from related parties in other countries.
Tax Hyperion Vol 13, Issue 1
Carswell’s Tax Hyperion published “Warning: Tax Authorities are Auditing Inter-Company Loans and Other Financial Transactions” by Matthew Wall.
Tax Hyperion Vol 12, Issue 12
Carswell’s Tax Hyperion published “Why Transfer Pricing Disputes are on the Rise for Companies of All Sizes” by Matthew Wall.
Bloomberg BNA Interview
Bloomberg BNA interviewed Matthew Wall for “Canadian Tax Court Judge Withdraws From Remaining Role in McKesson Case.”
McKesson Canada vs. The Queen
MDW commented on the Tax Court of Canada’s reasons for upholding the CRA’s reassessment, with costs, and the taxpayer’s reasons for appealing to the Federal Court of Appeal.
International Tax Review
International Tax Review interviewed Matthew Wall for “Reinsurance transactions under scrutiny in Canada.”
Transfer Pricing Week
Transfer Pricing Week published “Tax authorities using CUPs for pricing transactions” by Matthew Wall and David Jarczyk in response to earlier comments by Joseph Andrus at the OECD.
Transfer Pricing Litigation
MDW explained the Supreme Court dismissal in GlaxoSmithKline Inc. v. The Queen, sending it back to the Tax Court to include “embedded intangibles” in the price of the active ingredient.
International Tax Review
International Tax Review quoted Matthew Wall of MDW in “What you need to know about the OECD’s recent TP reports.”