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Applying the TPSM in Canada

The discussion draft on the application of the Transactional Profit Split Method (TPSM) presents the TPSM as a multi-sided transfer pricing method.

Canadian transfer pricing documentation: What you should know

The two transfer pricing memoranda released by the Canadian Revenue Agency on January 29, 2015 address intra-group services (TPM-15) and multi-year...

Managing Canadian investment entities in the U.S.

Investment entities in the United States that happen to reside in Canada now have detailed guidance for determining their status under the Foreign...

Managing non-Canadian private equity funds in Canada

Non-Canadian private equity fund sponsors can be subject to a number of Canadian tax issues when engaging Canadian service providers, raising capital...

Ontario Securities Commission narrows private party standing for public interest applications in contested transactions: The Corus Entertainment decision

In the Matter of the Catalyst Capital Group Inc. and In the Matter of Corus Entertainment Inc., the OSC determined not to grant standing to The...

Economic stimulus through infrastructure investment – The 2016 Alberta and federal budgets

The 2016 budgets recently released by the Alberta and federal governments include commitments to make significant investments in infrastructure.

Supreme Court of Canada clarifies meaning of “Indian”

The Supreme Court of Canada’s decision confirms that "Indians” under subsection 91(24) of the Constitution Act, 1867 includes all Aboriginal...

CSA publishes proposals for proxy vote reconciliation

The Canadian Securities Administrators published for comment proposed protocols for proxy vote reconciliation.

Potential impact of the New Quality of Care Information Protection Act, 2015 on hospitals

Bill 119, the Health Information Protection Act, 2015, was “carried on division” at second reading before the Legislative Assembly on February...

Revised Intellectual Property Enforcement Guidelines clarify the Competition Bureau’s approach in IP matters

Last week, the Competition Bureau released revised Intellectual Property Enforcement Guidelines after engaging in a lengthy consultation period based...