Canada, United States Canada Likely to Reciprocate U.S. Policy On APA Rollbacks, Post-Return Adjustments
September 30, 2010 in Transfer Pricing Report
By Molly Moses
While the Canada Revenue Agency does not officially preclude an advance pricing agreement for a taxpayer that increased income in a rollback year through filing an amended return, its policy may change depending on how reciprocal cases are treated in the United States, an Ottawa practitioner said Sept. 29.
Shiraj Keshvani of Deloitte Tax LLP said the CRA’s APA Program historically has…
Enjoying this article? To continue reading you need to take out a FREE trial to the Transfer Pricing Library.
Already a subscriber? Sign in here
Related Articles:
- Korea’s Third APA Report Shows Data On Renewals, Better Times for Bilaterals
- U.S., Canada See 80 Percent Reduction In Backlog of Cases Slated for Arbitration
- APA Officials Discuss New Procedures Including Scrutiny of Unilateral Submissions
- Danilack Praises Early Arbitration Experience With Canada, Says Conclusions Premature
- Implementing your transfer pricing policy
