In Kristen A. Parillo's article in
Worldwide Tax Daily (2013 WTD 139-7), "Lessons on Double Taxation Under the Canada-U.S. Tax Treaty", Claire Kennedy discusses the Federal Court of Canada's May 29 decision in
TeleTech Canada, Inc. v
Minister of National Revenue, in which the Canadian taxpayer was unable to compel CRA to participate in Competent Authority negotiations with the US to relieve double tax in a transfer pricing matter stating "it's a cautionary tale for taxpayers that you can't expect to get effective procedural relief through the judicial review process on the basis of the larger equities in the case."
Bennett Jones