CRA’s been aggressive for years—now Canada wants OECD-style “actual conduct” baked into the statute. Bill C-15 shrinks the doc clock to 30 days and makes “contracts say” a weaker defense when reality says otherwise. If your residual lives offshore but decisions live in Canada, expect the phone to ring.

The EU's Anti-Coercion Instrument—nicknamed the "trade bazooka"—lets Brussels retaliate against economic bullying without unanimous member state approval. Adopted in 2023, it authorizes tariffs, procurement bans, IP restrictions, and financial market exclusions against countries weaponizing trade to influence EU policy.

Built after Trump's 2018 tariffs and China's pressure on Lithuania, it's now facing its first real test: US threats over Greenland. The legal case looks clear—using tariffs to obtain territory is textbook coercion. But with $1.3 trillion in annual trade at stake, the political will to pull the trigger remains uncertain. Deterrence only works if your adversary believes you'll act.

Amount B promised to simplify transfer pricing for routine distribution—a genuine problem consuming six-figure fees on 3% margin transactions. Instead, it haunts the international tax system as a specter of what could have been. The 2025 OECD Model Convention builds elaborate dispute resolution infrastructure for a framework that, per France's July 2025 guidance, "no jurisdiction meets the conditions" to trigger. Developed economies won't implement domestically; covered jurisdictions haven't adopted. Only the US breathed life into it via Notice 2025-4—while simultaneously repudiating the Global Tax Deal. The ghost of transfer pricing simplification lives. It just hasn't found a body yet.