GE CANADA UPDATE: Why taxpayer’s attempts to strike CRA’s pleadings failed
January 05, 2012
Sophie Ashley - TPW
In the most recent stage of the GE Canada transfer pricing dispute, the taxpayer’s attempt to strike the Canada Revenue Authority’s (CRA) pleadings has failed.
While the initial dispute with GE Capital Canada was dealt with in 2009, and GE Capital Canada subsequently became GE Canada Company (GECC), the CRA has returned to the case. GECC was reassessed and denied the deduction of fees paid to its parent corporation GE US, for guaranteeing the inherited debts.
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