USA Transfer Pricing Case Law: Medtronic v. Commissioner, T.C. Memo. 2016-11

By Robert Robillard - 16 June 2016

This blogpost originally appeared on rbrt.ca. In Medtronic v. Commissioner, T.C. Memo. 2016-112, available here, the Court summarizes the main issues as follow: "(1) whether income related to intercompany licenses for the intangible property required to manufacture medical device pulse generators...

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Canada: Uncertain Tax Position Analysis not Safe from the CRA [2015 FC 714]

By Robert Robillard - 8 September 2015

This blogpost originally appeared on rbrt.ca. Canada (National Revenue) v. BP Canada Energy Company 2015 FC 714 provides an interesting glimpse into the upcoming tax audit world. Contrary to popular beliefs, this decision does not indicate that working papers should nowadays be...

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McKesson Canada Corp: Details of the Transfer Pricing Settlement with the CRA

By Robert Robillard - 26 August 2015

This blogpost originally appeared on rbrt.ca. As reported by Julius Melnitzer (Financial Post): "Documents filed by McKesson Canada Corp. with the U.S. Securities and Exchange Commission last month reveal that the company saved some $12 million in settling its high-profile...

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