CRA intimates that it is looking to get Cameco/Alta Energy reversed one way or the other
Although he did not state it this baldly, Ted Gallivan intimated, in the context of comments heard by him of Parliamentarians, that unless CRA gets a better result in the Supreme Court in cases such as Cameco (for which the period for applying for leave has not yet expired) and other FCA decisions (presumably including Alta Energy, for which leave was recently granted), then in order to protect the fisc, amendments to the ITA transfer pricing rules will be required.
Neal Armstrong. Summary of 2020 IFA-YIN Seminar on COVID-19 Guidelines, Q. 17 under s. 247(2)(b).