Précis: This was an appeal from a Tax Court decision blogged earlier on this site. The case involved transfer pricing, more specifically the disallowance of more than $7,000,000 in fees paid in 2000 and 2001 as well as the imposition of a penalty in excess of $500,000 for the 2001 taxation year. The Tax Court allowed the appeal, but only to the extent of permitting the deduction of fees in the amount of US$32,500 paid to Starline Windows Inc. (“SWI”) in each of 2000 and 2001. Costs were awarded to the respondent.
Marzen Artistic v. R. - FCA: Transfer pricing appeal dismissedREAD MORE »