Daniel Sandler, Lisa Watzinger, "Disputing Denied Downward Transfer-Pricing Adjustments", Canadian Tax Journal, (2019) 67:2, 281-308

Summary Under
Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(11)

Quaere whether s. 247(11) accords the TCC jurisdiction to hear an appeal of a s. 247(10) downward adjustment (p. 288)

[I]f subsection 247(10) is...

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Summary Under
Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(10)
Summary Under
Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(10)

Appeals Branch will not review s. 247(10) downward adjustments (p. 287)

[N]o one in CRA Appeals has delegated authority under subsection 247(10),...

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