Canadian Tax Court rejects reassessment inconsistent with MAP-Agreements in Sifto’s TP-case

May 03,2017

Tax Court of Canada rules in favor of Sifto Canada Corp (taxpayer), holds that reassessment made by Canadian Revenue Authority (CRA) for taxation year 2004 to 2006 were inconsistent with MAP agreement between Canada and USA; Pursuant to the 2008 reassessments issued by CRA on the basis of voluntary disclosure made by taxpayer, 2 MAP agreements were concluded and a commensurate reduction was made to the income assessed in the US, howev...

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