Feigenbaum Law

transfer pricing

Legal fees

Tax Disputes & Litigation

Cameco Awarded More than $10 Million in Legal Fees After Decade Long Dispute with the CRA

Canadian resource company Cameco, one of the world’s largest producers of uranium fuel, recently announced that it would be receiving $10.25 million in costs after a protracted battle with the Canada Revenue Agency (CRA) over alleged tax evasion. Some Background The dispute began when the CRA questioned Cameco’s corporate structure following the company’s reorganization in the late 1990’s. At issue was whether Cameco used a Swiss subsidiary, Cameco Europe Ltd. (CEL) as a means of… Read More

Tax Disputes & Litigation

Case Commentary – MAP Transfer Pricing Settlement is Binding on CRA

Earlier this year, the Tax Court of Canada released reasons in the case of Sifto Canada Corp. v The Queen. This decision addresses the legal impact of a transfer pricing settlement under the Mutual Agreement Procedure (“MAP”) article of the Canada-U.S. Tax Convention (“Treaty”), and determined that the Canada Revenue Agency (“CRA”) is bound by an earlier MAP settlement that set the transfer price for the transaction. Sifto Canada Corp. v The Queen The… Read More