CRA Principal, Paul Wilmshurst, provides a brief introduction to two key transfer pricing documents released by the OECD on July 30, including a “Revised Discussion Draft on Transfer Pricing Aspects of Intangibles” and a “White Paper on Transfer Pricing Documentation.”
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...