Transfer Pricing Rules in Canada: An Overview

Canada, like the U.S., imposes a thorough set of documentation requirements, and imposes penalties for failure to comply.

Valuation Considerations for Acquisition Structures

A key tax consideration is whether the acquirer will be entitled to a stepped up tax basis in the assets and thus entitled to future tax deductions.

Deferral of Cancellation of Debt (COD) Income Could Result in Substantial Tax Saving

Determining the degree of insolvency is a key step since this will dictate the amount of COD income which may be excluded.

Valuation Integral to Sec. 409A Requirements

The valuation of a development-stage company’s common stock is best estimated using the methods in the Practice Aid.

Tax Considerations During Troubled Economic Times

For companies who have not filed for bankruptcy, the insolvency exception is critical.

Valuation Plays Key Role in FIN 48 Compliance

Many companies have already adopted FIN 48 and have turned their attention to the annual disclosure requirements.

Cost Sharing Agreements an Effective Tax Planning Tool

The impact of the investor model is that it essentially guarantees a return to the intangibles developer for its efforts.

Purchase Price Allocations Support Section 338 Elections

In general, the impact of a Sec. 338 election is that a stock acquisition is treated as an asset acquisition.

Worthless Stock Deduction May Result in Tax Benefits

Obtaining a valuation from an independent valuation provider is essential to proving that the security has no liquidating value.