Words and Phrases - "reasonable efforts"
Brian Mustard, Sam Maruca, Charles Thériault, Richard Tremblay, "Transfer Pricing: What Are 'Reasonable Efforts,' and When should Penalties Apply?", Canadian Tax Foundation, 2015 Conference Report, 32:1-33
Unlikelihood of a s. 247(4)(a) safe harbour (p. 32:7)
[T]he qualitative assessment of the adequacy of the actions described in subsection 247(4)...
Words and Phrases
reasonable effortsLocations of other summaries | Wordcount | |
---|---|---|
Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2) | 110 | |
Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(4) - Paragraph 247(4)(a) | 102 |
Michael Colborne, Michael McLaren, Mark Barbour, "Subsection 247(3): What are "Reasonable Efforts"?", Canadian Tax Journal, (2016) 64:1, 229-43
Dictionary meaning of “reasonable efforts” (p. 236)
On the basis of these definitions, we believe that the ordinary meaning of "reasonable...
Words and Phrases
reasonable effortsLocations of other summaries | Wordcount | |
---|---|---|
Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(4) | 101 |