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Alert Indirect tax Transfer pricing Private sector consulting
Navigating trade uncertainty: Tax planning and transfer pricing strategies
Proposed U.S. tariffs on Canadian imports create uncertainty. Businesses must adapt supply chains, tax strategies, and operations to mitigate risks. We offer expert guidance.
Dean Morris Scott Dupuis Dec 12, 2024
Tax alert (Use going forward)
Alert Audit and assurance International Transfer pricing
Bring it back - Repatriating profits from Canada to the U.S.
In our latest Tax Alert, we explore repatriation planning, focusing on the most effective tax strategies for a Canadian subsidiary to repatriate profits to its U.S. parent corporation.
Mandeep Gaheer Sep 12, 2023
Tax alert (Use going forward)
Transfer pricing
A guide to transfer pricing
The complicated world of transfer pricing just got easier to understand. Our new specialty transfer pricing service helps businesses navigate this complex area of corporate tax.
May 26, 2023
04 AERIAL
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Transaction services Audit and accounting Private enterprise Tax advisory Transfer pricing
The capital gains exemption: beware of in-law quirks
In Canada, qualified farmland can be transferred from one generation to the next for any dollar amount between cost and fair market value (FMV) at the time of the transfer. Any capital gain triggered by the transfer is covered by the capital gains exemption (up to $1,000,000 for farmland), assuming the land is qualified farm property.
Mar 2, 2018
20 PEOPLE
International Indirect tax Tax advisory Transfer pricing
Budget 2017 Update - Relief for contingency fee engagements
<em>This information is current to May 11, 2017. Please refer <a href="/en/cbn/publications/taxflash-budget-2017-update-relief-for-contingency-fee-engagements" target="_blank">here</a> for an updated version of this Tax Flash. </em> As proposed in the March 22, 2017 budget, every professional must include year-end work-in-progress (WIP) into taxable income effective for taxation years beginning after March 21, 2017. WIP for professionals typically represents unbilled professional time and cost incurred in the rendering of services to clients. This is often captured in the form of a professional’s “charge-out” rate, which represents their cost, overhead and some profit component.
May 11, 2017
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Tax advisory Transfer pricing
Revenue recognition for construction contracts under IFRS 15
The timing of revenue recognition may need to change in the near term for a construction entity preparing IFRS financial statements. Specific accounting guidance on construction contracts contained in IAS 11 Construction Contracts is replaced effective for annual reporting periods beginning on or after January 1, 2018. The International Accounting Standards Board (IASB) has published a new standard, IFRS 15 Revenue from Contracts with Customers (IFRS 15). IFRS 15 sets out requirements for recognizing revenue that apply to all contracts with customers. 
Apr 26, 2017
On The Mark-Revenue recognition for construction contracts under IFRS 15
Audit and accounting International Transfer pricing
“Smaller” multinational enterprises & transfer pricing
<h3>How saving $20K nearly cost this taxpayer $2.7 million!</h3> It seems that every day now there is an article of some sort addressing aggressive tax structures, often utilizing offshore entities, and the ramifications of (implied) inappropriate, underlying transfer pricing policies. Recently, this has clearly been due to the news of the “Panama Papers” disclosure or, more generally over the past couple of years, the result of the recently finalized <a href="/en/cbn/publications/beps-the-final-reports-1" target="_blank">Base Erosion and Profit Shifting Project reforms published by the Organisation for Economic Co-operation and Development</a>.
Jun 8, 2016
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International Tax advisory Transfer pricing
Financing a U.S. Subsidiary: Debt vs. Equity
Canadian corporations seeking to expand their operations often look southward to grow their business. By expanding into the United States, Canadian corporations can potentially gain access to a much larger market than is available in Canada. For a variety of valid reasons, Canadian corporations often choose a U.S. corporation as a vehicle for expansion into the U.S. But once this structural decision is made, the question becomes, how to finance the U.S. operations?
May 31, 2013
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International Tax advisory Transfer pricing
Our American Customers: the Watchdogs of the U.S. Tax System
With today’s technology, it is becoming increasingly easy to sell products to individuals and companies all around the world. Many Canadian companies have developed great business relationships with U.S. customers, selling a wide variety of goods.
May 31, 2013
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International Tax advisory Transfer pricing
2013 Federal Budget Commentary: “Jobs, Growth and Long-Term Prosperity” - March 21, 2013
The Honourable Jim Flaherty, Minister of Finance, today tabled Canada’s Economic Action Plan 2013, a budget focused on balancing the budget during this Parliament. This budget introduces skills training initiatives, a federal infrastructure plan and new investments to support manufacturing and innovation in Canada.
Mar 22, 2013
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Tax advisory Transfer pricing
Transfer Pricing: the T106 Form and Related Penalties
The T106 Summary and corresponding Slips (collectively, the T106 Form) represent the annual information return used to report non-arm’s length transactions between reporting persons or partnerships and non-residents, in accordance with section 233.1 of the Income Tax Act.
Mar 13, 2013
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