Tax Tax

Manitoba proposes expanded sales tax collection and remittance requirements in 2021 budget

In its 2021 budget, Manitoba proposed certain changes that will expand the scope of the requirements for businesses to collect and remit Manitoba...

The Supreme Court of Canada upholds the constitutionality of federal carbon pricing legislation

On March 25, 2021, the Supreme Court of Canada released its much-anticipated decision, upholding the constitutionality of the Greenhouse Gas...

Supreme Court of Canada hears Alta Energy appeal on benefits under tax treaties

On March 19, 2021, the Supreme Court of Canada heard the Crown's appeal in Canada v Alta Energy Luxembourg SARL, a case in which the Crown took the...

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...

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....