CRA’s Robin Hart designed and operationalized a global services profit split transfer pricing policy for a digital services agency. The analysis identified and rewarded entrepreneurial activity within the network and gave the company flexibility regarding customer contracts and employee location with increased remote working. CRA further assisted the client by providing a workbook for the quarterly profit split computation.
Who bore the tariff burden? Economics of IEEPA refund disputes
The refund question sits at the intersection of customs procedure, administrative law, but also economics, and resolution will likely vary significantly across...