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Steven Hannes advises US- and foreign-based multinational corporations on developing their cross-border transactions, and counsels multinational companies in tax controversies. Steven represents clients on matters at the Audit, Appeals, Competent Authority and the Advance Pricing Agreement offices of the Internal Revenue Service (IRS). He is recognized nationally for creating and defending structures and contractual arrangements that involve intra-group transactions and prices for intellectual property, goods and services. He has also presented expert testimony on tax treaties in court. Read Steven Hannes' full bio.
Canadian Tax Court Holds that Agreements Reached Under the Mutual Agreement Procedure are Binding on the Canada Revenue Agency
By K. Christy Vouri-Misso and Steven Hannes on May 9, 2017
Posted In Court Procedure Matters, Transfer Pricing Resource, Trial Courts, Uncategorized
On March 10, 2017, the Tax Court of Canada held that agreements reached under the Mutual Agreement Procedure (MAP) precluded the Canada Revenue Agency (CRA) from redetermining the transfer prices of rock salt sold by Sifto Canada Corp. (Sifto Canada) to a related party in the United States. In 2006, Sifto Canada reevaluated the transfer...