Budget 2012: transfer pricing amendments proposed *

Canada - March 31 2012
The Income Tax Act (Canada) (the "Tax Act") contains an extensive set of transfer pricing rules designed to ensure that cross-border transactions entered into between Canadian taxpayers and non-residents with which they do not deal at arm's length are priced on an "arm's length" basis.

Co-authors: Ryan L. Morris, Mickey M. Yaksich, Peter Botz.

Budget 2011: extension of the super flow-through share program *

Canada - March 25 2011
Budget 2011 proposes to extend the "super flow-through share" program for an additional year.

Co-authors: Ryan L. Morris, Peter Botz.

New collateralisation rules for unlicensed reinsurance *

Canada - February 28 2011
As promised, the Office of the Superintendent of Financial Institutions (OSFI)1 issued the final version of its new guidance on reinsurance security agreements before the end of 2010.

Co-authors: Rob Scavone, Carol Lyons.

Update on demand obligations *

Canada - June 9 2010
Shortly after Ontario's Limitations Act 2002 (the "Act") came into force in January of 2004, we wrote a Banking and Project Finance Brief to describe the impact the Act would have on the financial services community, including its application to demand obligations.