Canada Revenue Agency’s Responses from Tax Executive Institute Questions The Tax Executive Institute (“TEI”) recently published written responses from their annual liaison (held on December 4-5, 2012) with the Canada Revenue Agency (“CRA”). Click here  Of note are the questions related to transfer pricing: Question 10 … Read more

EMG Transfer Pricing Experts and Tax Chambers invite you to a joint presentation. Transfer pricing developments during 2012 will have an impact on many multinational enterprises. The developments include: the restructuring of the IRS, the decision by the Supreme Court on the first transfer pricing case to … Read more

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Guarantee Fees: The recent Canadian litigation of GE Capital and the controversial 2010 Taxation Ruling in Australia, TR 2010/7 brought global attention in respect of the treatment of related party cross-border guarantee fees. Unfortunately, the litigation and tax ruling did not significantly reduce this uncertainty in … Read more

We are pleased to announce the launch of our new corporate identity; EMG Transfer Pricing Experts Inc. We are a transfer pricing firm that advises companies on their related cross border transactions under the continued leadership of Merv Edwards and Dean Morris.