Google, Starbucks, Amazon - some of the biggest businesses in the Western world have been embroiled at some point in high-stakes tax disputes over transfer pricing. Yet, international tax woes are not confined to blue-chip corporations. Any business with corporate...
Calgary Corporate Law Blog
The basics of the law, the guidelines, the circulars, the TPMs, and how they relate to Canadian transfer pricing
An understanding of the nature and significance Provisions of Canadian law, the OECD guidelines (Guidelines), and the administrative circulars and memoranda of the Canada Revenue Agency (CRA) as set forth in Circulars and Transfer Pricing Memorandums (TPM) is critical...
Should I incorporate my business provincially, or federally?
When a Canadian small business is ready to incorporate, it has two options: Provincial or federal incorporation. The way in which a business incorporates can have long-lasting implications for its success. It is important for business owners to choose the method of...
Post BEPS Transfer Pricing
Shaun MacIsaac commented on current post- BEPS issues including the new landmark Chevron case ... Shaun T. MacIsaac, Q.C. appeared with a panel of international experts at the Sofitel Hotel, London, UK on November 22, 2017, and provided comments that related to the...
Selling a business – Determining the right purchaser
You've built a successful business in Alberta, and the time comes that you consider selling it. Likely, your primary concerns are to find the right buyer and attain the best purchase price. However, you might also have serious concerns about maintaining the brand...
Purchase and Sale
In the coming years, pundits have predicted that a trillion dollars of assets are to be transferred from current owners to the new generation in Canada over the next decade. Orderly planning for the tax, asset protection and wealth building opportunities have to be...
Acquisition International Dispute Resolution Awards – Best for Transfer Pricing Disputes Canada – 2015
Acquisition International have conferred the award to for "Best for Transfer Pricing Disputes - Canada" for 2015. The firm is thrilled to be recognized internationally based on the criteria of peer review in this highly specialized...
Paskapoo Slopes Development Plan approved
The public hearing on the application for the Policy Amendment with respect to the proposed Paskapoo Slopes development was front and centre on July 27, 2015 as Calgary faced a real policy choice regarding the development of the privately owned land of environmental...
Cancelling the increases makes sense
Earlier this year, the Alberta government proposed a six-fold increase in most major Land Titles document registration costs. The stated purpose was one of several measures to cover an expected shortfall in government revenues. I think that the increased costs would...
Submission of PMR Law to OECD Regarding Risk and Non-Recognition of Contracts
Written Comments on the Revised Discussion DraftChapter 1, Risk, Recharacterization and Special MeasuresThe OECDParis, FranceFebruary 5, 2015 Re: Risk, Recharacterization and Special Measures CommentsThese comments are made by Shaun T. MacIsaac, Q.C., on behalf of the...
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PMR Law have been named the winner of the Business Law Firm of the Year 2017 Canada by CV Magazine and the Global 100 Excellence Award as Firm of the Year (Litigation Counsel) Canada. These awards are much appreciated by the firm. In everything we do, we strive to provide the best service for our clients.