Tax Tax

Supreme Court denies Crown’s request for leave to appeal Cameco transfer pricing decision

On February 18, 2021, the Supreme Court of Canada declined the Crown’s application seeking leave to appeal the June 2020 decision of the Federal...

Federal Court of Appeal decides that Visa services to CIBC are exempt financial services, not administrative services for GST/HST purposes

On January 22, 2021 the Federal Court of Appeal released its reasons in Canadian Imperial Bank of Commerce v. The Queen, 2021 FCA 10, overturning the...

Osler submission on the OECD Pillar One and Pillar Two Blueprints

Earlier in 2020, the OECD published blueprint reports on Pillar One and Pillar Two and launched a public consultation process on its two-pillar...

A year of upheavals and dashed expectations: Executive compensation developments in 2020

Executive compensation plans were upended in 2020 as a result of the dramatic impact of the COVID-19 pandemic on business plans and the extraordinary...

Novel hybrid debt issuances by Canadian banks

Hybrid debt is debt with embedded equity features that are added to meet requirements imposed by a regulator, rating agency or some other third party...

Flexibility in the financial market in response to major changes

This year, financial market participants have been subject to many unprecedented changes that have forced them to show a great deal of flexibility....

COVID-19 tax measures and proposed international tax reform

Two significant tax developments in 2020 were Canada’s measures in response to COVID-19 and Canada’s participation with the OECD’s pursuit of...

From treaty shopping to FAPI and transfer pricing: Notable international tax cases

Three decisions of the Federal Court of Appeal (FCA) released during the COVID-19 pandemic have caused renewed interest in certain fundamental...

2020 Legal Year in Review – Introduction

Without a doubt, 2020 has been a year like no other. Inevitably, the COVID-19 pandemic and its effects is a theme that flows through many of the...

OECD releases blueprint reports on international tax reform (Pillar One and Pillar Two) and launches public consultation

The OECD recently released blueprint reports on Pillar One and Pillar Two and launched a public consultation process on its two-pillar approach to...