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| Canadian Firm Pays One-Off Tax Charge Over Barbados Restructuring |
by Mike Godfrey, Tax-News.com, Washington
Friday, January 09, 2009
Gildan Activewear Inc., the Canadian clothing manufacturer and marketer, recently
announced that it had reached a final agreement with the Canada Revenue Agency
(CRA) with respect to the audit of the company’s tax filings for its 2000-2003
fiscal years.
The company announced last month that, except for a one-time charge, no significant
income tax adjustments to previously reported income tax rates or after-tax
income for the 2000-2003 fiscal years have resulted from the CRA audit.
Based on the results of the audit, and the outcome of its discussions with
the CRA regarding Gildan’s transfer pricing methodology and other audit
matters, the company disclosed that it "continues to be comfortable with
its income tax provisions for fiscal years subsequent to the period covered
by the audit."
The company reported a low consolidated tax rate because the majority of its
profits are earned and taxed in Central America and the Caribbean Basin, where
its sales, marketing and manufacturing functions are managed and performed.
Gildan has agreed to a one-time tax assessment in respect of the restructuring
of its international wholesale business and the related transfer of assets to
its Barbados subsidiary in fiscal year 1999.
The assessment has resulted in a charge in the fourth quarter of fiscal 2008,
amounting to approximately USD27m or USD0.22 per share, including a provision
for provincial taxes.
The company accepted the one-time assessment in order to avoid a lengthy negotiation
process with the tax authorities, which could have resulted in prolonged uncertainty
with regard to Gildan’s overall effective income tax rate.
The company will also make an additional cash payment of approximately USD17m
for income tax liabilities which had previously been recorded and reserved in
prior years and reflected in the company’s income tax rate as reported
for these years.
A comprehensive report in our Intelligence Report series
looking at offshore and onshore corporate structures and their tax implications
is available in the Lowtax Library at http://www.lowtaxlibrary.com/asp/subs_reports.asp
and a description of the report can be seen at
http://www.lowtaxlibrary.com/asp/description_report7.asp
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