250111 – Economic Substance Challenged in France: French Administrative Supreme Court Upholds Recharacterization of Equity as Intercompany Loans
Authors: Sebastian Rheault, McShane Jones, and Vincent Lepaul
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250110 – Bruyea v. United States and the Independent Treaty Credit
Authors: H. David Rosenbloom and Fadi Shaheen
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250109 – Susquehanna: Irish High Court Considers the TCC’s TD Securities Decision
250108 – Highlights of the CRA Round Table at the 2024 CTF Annual Conference
Authors: Samantha D’Andrea and Sam Li
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250107 – Update on Status of Pillar 1 and Pillar 2
Authors: Patrick Marley and Oleg Chayka
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250106 – Import Tariffs and Export Taxes: A Practical Review
Authors: Rob Kreklewetz and John G. Bassindale
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250105 – A Blue Jays Home Run Over a Wild CRA Pitch: Setting Tax Jurisdiction for Sourced Income
Authors: Balaji (Bal) Katlai and Hugh Neilson
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250104 – BlackBerry Limited v. The King: Modernizing the Base Erosion Rules
250103 – When a Non-Resident Might Qualify as a “Parent” Under the FAD Rules: A Potential for Retroactive Application?
Authors: Mark Jadd and Daniel Safi
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250102 – Impact of New Capital Gains Rate on Non-Residents and Overseas Operations
Authors: Chetna Thapar and Daniel Mahne
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