Canada vs Sifto Canada Corp, March 2017, Tax Court, Case No TCC 37

Posted on | By Courts of Canada
Category: Legality - Legitimacy - Constitutional, MAP - APA, Tax Treaty Interpretation | Tag: , ,
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The issue before the court was whether the Canadian revenue service had the ability to issue the second reassessments given the Canadian and US competent authorities subsequently agreed on a MAP settlement.

The Tax Court found that a settlement agreed to via the competent authority precluded a subsequent tax-reassessment that attempted to further increase the taxpayer’s income.

Related Guidelines

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