In this article from Tax Notes International, Davies partner Nathan Boidman contends that the sponsors of the Tax Cuts and Jobs Act not only failed to deliver on their promise of a territorial system for controlled foreign corporations, but also expanded the pre-existing quasi-worldwide system.
Federal Court of Appeal Confirms CRA Can Collect Arrears Interest Despite Absence of a Tax Debt
Dec. 04, 2024 - The Federal Court of Appeal (FCA) recently dismissed the Bank of Nova Scotia’s (BNS) appeal and upheld the Canada Revenue Agency’s (CRA) practice of charging arrears interest on a non-existent tax debt where audit adjustments increase taxable income that is offset by the carryback of a loss...
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...
