Tax Advisory Services

136 countries agree to OECD/G20 Inclusive Framework’s two-pillar solution to international tax reform

Last week, 136 countries, including Canada and the United States, announced that they have agreed to the OECD/G20 Inclusive Framework’s two-pillar...

A discordant jurisprudence: what does it mean to be ‘Acting in Concert’?

Under the Income Tax Act (Canada) taxpayers are deemed to not deal at arm’s length if they are “related”. In all other circumstances, taxpayers...

New CRA guidance on input tax credit allocation methods for financial institutions under section 141.02 of the Excise Tax Act

The Canada Revenue Agency recently released new guidance on #inputtaxcredit allocation methods for #financial institutions. In their Osler Update,...

OECD/G20 Inclusive Framework reaches high-level agreement on two-pillar approach to international tax reform

In their Osler Update, authors Patrick Marley, Peter Macdonald, Kaitlin Gray and Taylor Cao comment on the statement by the OECD/G20 Inclusive...

G7 Finance Ministers back international tax reform (Pillar One and Pillar Two), including introducing a global minimum tax of at least 15%

On June 5, 2021, the Finance Ministers from the G7 group of leading economies (including Canada) committed to the principal design elements for the...

Federal budget briefing 2021

A summary of the significant tax proposals included in Budget 2021. Find out how these tax changes will affect Canadians and Canadian businesses.

Continued uncertainty following recent CRA position on Tax Treaty anti-avoidance rule

The most significant treaty modification implemented through the MLI was the addition of a broad anti-avoidance rule known as the principal purpose...

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...

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...