The Supreme Court ruled 6-3 that IEEPA does not authorize presidential tariffs. Roberts held that "regulate … importation" doesn't include the power to tax — a power the Constitution reserves to Congress. The ruling invalidates the reciprocal and drug-trafficking tariffs but leaves Section 232/301 duties intact. Refund exposure may top $175B. The administration vows to reimpose tariffs under other statutes, but those tools are narrower, capped, and require formal investigations IEEPA never demanded.

India just collapsed four safe harbor categories into one, cut the margin to 15.5%, and raised the threshold to ₹2,000 crore — which means the annual benchmarking fight that has defined Indian TP compliance for two decades might actually be over for most IT services captives. But "streamlined" is not "free," and the price of certainty includes a margin above arm's length, secondary adjustment obligations, and surrendering your right to MAP. This article explains what changed, what it costs, what still applies, and why India decided now was the moment to stop auditing its way to an answer everyone already knew.

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.