Patrick Marley Patrick Marley

Canadian anti-hybrid tax legislation released in draft

On April 29, 2022, the Department of Finance released the first of two packages of draft legislation to implement its proposals to eliminate the tax...

OECD releases model rules for global minimum tax

The OECD released model rules for the proposed global minimum tax under Pillar Two of the OECD/G20 Inclusive Framework.

Tax planning developments: Important international tax changes

In 2021, a number of significant changes were proposed for international taxation in Canada. Find out more about what changes were introduce in 2021...

Supreme Court releases Alta Energy decision: taxpayer wins, application of GAAR to tax treaties clarified

Earlier today, the Supreme Court of Canada released its decision in Canada v. Alta Energy Luxembourg S.A.R.L., 2021 SCC 49.

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...

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...

Exchangeable share structures – an overview

Exchangeable share structures have been a fixture in structuring cross-border share exchange mergers and acquisitions involving Canadian corporations...

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...

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...

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...