CRA assisted a software company with the integration of acquired technology into an existing qualified cost sharing arrangement with consideration of the appropriateness of carve-outs. Additional work included the alignment of functional returns for acquired subsidiaries with the transfer pricing policies of the acquirer.
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...