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

By Robert Robillard - 16 juin 2016

This blogpost originally appeared on 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 septembre 2015

This blogpost originally appeared on 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 août 2015

This blogpost originally appeared on 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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