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McKesson: appellant’s factum filed

By Shaira Nanji

On 10 January 2014, McKesson Canada Corporation appealed the decision of the Tax Court of Canada in McKesson Canada Corporation v The Queen (2013 TCC 404).

In McKesson, the Tax Court upheld the Canada Revenue Agency’s transfer price adjustments (made pursuant to section 247 of the Income Tax Act [Canada]) that had reduced the discount rate paid under a receivables sales agreement between McKesson Canada and its parent company, MIH, from 2.206 per cent to 1.013 per cent. The Tax Court also upheld the assessment of withholding tax on a deemed dividend that arose in a secondary adjustment resulting from the lower discount rate…

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