When the US Treasury Department and Internal Revenue Service (IRS) announced the postponement of key dates in the implementation of the Foreign Account Tax Compliance Act (FATCA), foreign financial institutions breathed a sigh of relief.
Tis the season for tax policy. The OECD and the UN have been busy drafting reports on tax and transfer pricing, all of which have been released this month.
The SC dismissed the appeal by the Canada Revenue Agency (CRA) of a ruling by the Federal Court concerning the deductibility of the price paid by GSK Canada to a Swiss related-entity. The CRA said the payment was not reasonable in the circumstances and a reasonable payment would have been that paid by generic companies.
