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Doing Business in Canada 2017
  • McCarthy Tétrault LLP
  • Canada
  • May 3 2017

What are the key considerations when planning to establish or acquire a business in Canada? What are the potential opportunities, and where are the


Rio Tinto Alcan v. The Queen: Welcome Expansion of the Canadian Tax Deductibility of M&A Transaction Expenses
  • Bennett Jones LLP
  • Canada
  • February 24 2017

In a welcome decision for Canadian acquirors and targets, the Tax Court of Canada recognized, in Rio Tinto Alcan Inc. v The Queen, that certain


Canada’s Upstream Loan Rules - 2017 Update
  • Thorsteinssons LLP
  • Canada
  • February 6 2017

Canada's so-called "upstream loan rules" were enacted in 2011 to protect the integrity of Canada's detailed foreign affiliate rules. In broad terms


Legal Year in Review
  • Osler Hoskin & Harcourt LLP
  • Australia, Canada, Ireland, OECD, USA
  • December 6 2016

Osler's insights on key developments in 2016 and their implications for Canadian business


Doing Business in Canada, An Introduction to the Legal Aspects of Investing and Establishing a Business in Canada
  • Borden Ladner Gervais LLP
  • Canada
  • December 2 2016

This guide provides a practical overview of Canada's legal landscape to international businesses looking to establish operations in Canada or


Ghislain Poulin And Herman Turgeon v. Her Majesty The Queen, 2016 DTC 1129
  • Borden Ladner Gervais LLP
  • Canada
  • September 13 2016

L’Amiante’s corporate structure was reorganized to facilitate the departure of the taxpayer Mr. Poulin, and to integrate Mr. Hélie into the company


Tax Court Allows Deduction for Advisory Fees in M&A Transaction
  • Bennett Jones LLP
  • Canada
  • July 22 2016

The Tax Court of Canada has recognized in a recent case that “oversight expenses” - notably investment banking and other professional advisory fees


TCC applies the GAAR to treat post-takeover steps as a cross-border surplus strip
  • Thorsteinssons LLP
  • Canada
  • July 1 2016

In Univar Holdco Canada ULC v. The Queen, 2016 TCC 159, a UK private equity firm (CVC) acquired all the shares of Univar NV (a Netherlands public


Interest Deductibility in Canada: The TDL Group Co. Decisions
  • Davies Ward Phillips & Vineberg LLP
  • Canada
  • June 3 2016

Last summer, one of the writers and two colleagues examined1 the then-recently issued decision of the Tax Court of Canada (TCC) in TDL Group Co. v


CRA rules that foreign “share premium account” could be converted to PUC on continuation into Canada
  • Thorsteinssons LLP
  • Canada
  • May 20 2016

In 2015-0584151R3 (recently released), a widely-held foreign public parent company (Pubco) continued into Canada under provincial corporate law. As