2404 | International Tax Highlights, November 2024
Editor: Angelo Nikolakakis Volume 3, Number 4, November 2024 Access the November 2024 Issue PDF
240401 – In This Issue
Author: Angelo Nikolakakis
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240311 – HMRC v. Burlington Loan Management DAC
240310 – UK Upper Tribunal Dismisses HMRC’s Appeal: Treaty Reduction Not a Main Purpose of Transfer
Authors: Chris Sheridan, Jeffrey Shafer, and Jessica Charendoff
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240309 – PepsiCo Appeal: Fizzle It Is, Then, for Withholding Tax on Embedded Royalties?
Authors: Sébastien Rheault, Jing Yu Wang, Julien Tremblay-Gravel, and Yu Chen Ding
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240308 – Regulation 105 and the Reimbursement of Subcontractor Fees: Recent Change in the CRA’s Position
Authors: Pouyan Zabihian and Laura Gheorghiu
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240307 – Inbound Investments: Traps for SR & ED Tax Credits
Author: Balaji (Bal) Katlai
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240306 – Canadian Tax Concerns Arising from the Use of Professional Employer Organizations
240305 – Gambling with the PPT
Authors: Xavier Plomteux and Marie-Emmanuelle Vaillancourt
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240304 – CRA International Tax Round Table
Authors: Derek Chiasson and Mélissa Dorsaint
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