The CRA’s updated Transfer Pricing Memorandum (TPM-05R) clarifies the CRA’s process for requesting contemporaneous documentation and includes specifically four new sections, such as method of delivery, three-month delivery, documents provided to CRA and reasonable efforts. By preparing contemporaneous documentation, taxpayers make some assumption and do some avoidable errors. The position of the CRA is that these changes will help to resolve the false presumption and avoidable errors.
IRS warns filing deadlines for US Expats
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