As Two-Year Deadline Looms for U.S.-Canada Arbitration, Practitioners Discuss APA Coverage, Other Unresolved Issues
September 23, 2010 in Transfer Pricing Report
By Molly Moses
With U.S. and Canadian officials scheduled to discuss binding arbitration at the American Bar Association tax section meeting in Toronto Sept. 24, practitioners examined possible scenarios under which the joint guidance anticipated from the governments would cover advance pricing agreements and other issues.
The first cases under the Dec. 15, 2008, U.S.-Canada protocol will become eligible for arbitration two years from that date, which means U.S. and Canadian officials have less than three months to execute a memorandum of…
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