240403 – Impact of Capital Gains Realized by Foreign Affiliates and Treatment of Other Income
Authors: Hetal Kotecha and Daryl Maduke
Membership Required. If you have an active membership, you can login here.
Membership Required. If you have an active membership, you can login here.
240402 – Mind the Gap: FABI Relief Falls Short for CCPCs
Authors: Christopher Montes, John Farquhar, and Evan Raymer
Membership Required. If you have an active membership, you can login here.
Membership Required. If you have an active membership, you can login here.
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
Membership Required. If you have an active membership, you can login here.
Membership Required. If you have an active membership, you can login here.
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
Membership Required. If you have an active membership, you can login here.
Membership Required. If you have an active membership, you can login here.
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
Membership Required. If you have an active membership, you can login here.
Membership Required. If you have an active membership, you can login here.
240308 – Regulation 105 and the Reimbursement of Subcontractor Fees: Recent Change in the CRA’s Position
Authors: Pouyan Zabihian and Laura Gheorghiu
Membership Required. If you have an active membership, you can login here.
Membership Required. If you have an active membership, you can login here.
240307 – Inbound Investments: Traps for SR & ED Tax Credits
Author: Balaji (Bal) Katlai
Membership Required. If you have an active membership, you can login here.
Membership Required. If you have an active membership, you can login here.
