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Daily Tax Report: International

Cameco’s $368 Million Tax Fight to Examine Offshore Profits (1)

Nov. 3, 2020, 3:34 PM; Updated: Nov. 3, 2020, 9:17 PM

Uranium mining giant Cameco’s multi-million dollar tax dispute with Canada hinges in large part on how far tax authorities can go in recharacterizing revenue of offshore companies.

The Canada Revenue Agency says that a subsidiary’s profits could be reallocated to a parent company on the basis that their transactions would never have happened if they had been at arm’s length—the process by which multinationals value transactions between their entities as if they were unrelated.

The CRA lost this argument before the Tax Court in 2018 and the Federal Court of Appeal in June 2020. It appealed its case Oct. 30...

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