In this article from Tax Notes International, Davies partner Nathan Boidman reviews Marzen Artistic Aluminum, a Canadian transfer pricing case involving sales of Canadian products into U.S. markets. Nathan focuses on novel issues raised by the parties’ use of a Barbados subsidiary in the operating structure and the separate question of the decision’s possible effects on the implementation in Canada of any of the action 8-10 recommendations under the OECD’s base erosion and profit-shifting project.
U.S. Supreme Court Upends 40 Years of Judicial Deference to Regulations
July 25, 2024 - In a historical opinion in Loper Bright Enterprises v. Raimondo, Secretary of Commerce, released at the end of June, the U.S. Supreme Court overturned the “Chevron” doctrine, which for so long had controlled judicial review of U.S. federal regulations. Chevron, decided in...
Canada Finally Enacts the Digital Services Tax (Maybe)
July 09, 2024 - The new Digital Services Tax Act came into force with an order-in-council on June 28, 2024, imposing a 3% digital services tax (DST) on certain Canadian-source digital services revenue of large entities. The DST would first be payable in 2025, with the initial payments retroactively...
