CRA resolved an issue at Appeals relating to management fees for a Silicon Valley client. At issue was the beneficial allocation of expenses and the measurement of stock-based compensation. Rebel Curd successfully argued that the client’s beneficial allocation percentage was the most objective measure and that the client maintained sufficient books and records for the use of the fair value method for the inclusion of stock-based compensation. The case was resolved with zero adjustment.
Highlights from 2025 and looking forward to 2026
In the United States, 2025 brought major activity in high profile transfer pricing disputes and reaffirmed how closely transfer pricing, tariffs, and customs...