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Managing the Tax Residency of Foreign Affiliates in the Face of the COVID-19 Restrictions

The COVID-19 pandemic has resulted in the imposition of travel restrictions by governments and businesses. While such restrictions are no doubt valuable in "flattening the curve", they do, amongst other things, pose...more

No Appeal of BP Canada Decision on Working Papers, Announces CRA

The Canada Revenue Agency (CRA) has announced that it will not seek leave to appeal the Federal Court of Appeal's decision in the BP Canada case. This means that the Court's decision to deny the CRA general and unrestricted...more

No Routine Access by CRA to Tax Working Papers Rules the Federal Court of Appeal

The Federal Court of Appeal has limited the Canada Revenue Agency's (CRA) access to tax accrual working papers that reveal a taxpayer's uncertain tax positions. This case is an important one for every company that has audited...more

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