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...
Calgary Corporate Law Blog
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...
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...
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...
Leading Canadian transfer pricing cases favour domestic rules over OECD guidelines by Shaun T. MacIsaac, Q.C.
Leading Canadian transfer pricing cases favour domestic rules over OECD guidelines by Shaun T. MacIsaac, Q.C.TP Week Issue, August 21, 2014 - Until the decision in the GlaxoSmithKline (Glaxo) case, all previous Canadian court decisions had slavishly applied the OECD...
OECD Presentation Regarding Legal Ownership of Intangibles
Multinational enterprises ("MNEs") seek to comply with the laws of the jurisdictions within which they operate, including transfer pricing laws. The OECD promotes world trade by preventing double-taxation. All stakeholders, including tax authorities seek clarity and...
The Perils of Undue Reliance on Competent Authority
In the decision on Teletech Canada Inc. v. Minister of National Revenue 2013 FC 572 dated May 29, 2013, the Tax Court of Canada considered a request by the taxpayer to have the mutual agreement procedure (the "MAP") in the Canada -US tax treaty (the "Treaty") apply to...
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Award-Winning Service
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.