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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...

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...

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...

Update on implementation of the Multilateral Instrument in Canada

Canada is in the process of ratifying the Multilateral Instrument into Canadian law through Bill C-82, which is currently at third reading in the...

Canada tables NWMM to ratify MLI; Updates MLI reservations

Canada takes next step toward ratifying the MLI (to implement certain tax treaty changes), and removes some of its prior reservations. Learn more.