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Transfer Pricing Update Canada ( May 2006 )
During the past year, the Canada Revenue Agency ("CRA") has made transfer pricing a priority issue in its audits and has encouraged applications for bilateral Advance Pricing Agreements ("APAs"). The CRA also released a new transfer pricing memorandum dealing with requests for contemporaneous documentation and is implementing programs aimed at improving the quality of transfer pricing documentation prepared by CRA auditors. -
IRS Revises Scope of Tax Shelter Regulations LimitingCoverage of Confidential Transactions ( January 2004 )
On December 29, 2003, the Treasury Department and the IRS issued revised regulations that dramatically limit the circumstances under which a confidential transaction must be disclosed under the tax shelter rules. In addition, the IRS issued new rules intended to increase transparency and disclosure of information by taxpayers to deter abusive tax avoidance transactions. -
Corporate Tax Shelters--What Will Be the Impact of the New Regulations on U.S. Multinational Corporations? ( October 2001 )
Introduction In late February of this year, the Internal Revenue Service issued three sets of temporary and propo. -
Recent Changes to Disclosure Rules for Certain Tax-Exempt Organizations ( September 1999 )
This alert summarizes the Internal Revenue Service's changes to the disclosure rules for certain tax-exempt organizations. -
Y2K ( March 1999 )
Information and Readiness Disclosure Act President Clinton recently signed into law the Year 2000 Information a.
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