Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 07 JANUARY 2019

Case Comment: Cameco Corporation v. The Queen

Gardiner Roberts LLP
Gardiner Roberts LLP
Contributor
Explore more from Gardiner Roberts LLP

This case involved a landmark transfer pricing dispute in which the Canada Revenue Agency (the "CRA") reassessed the taxpayer for additional income of CAD$483,431,713 for the years 2003-2006 ...

CanadaTax
Lorne Saltman
Lorne Saltman
Author LinkedIn connections

This case involved a landmark transfer pricing dispute in which the Canada Revenue Agency (the "CRA") reassessed the taxpayer for additional income of CAD$483,431,713 for the years 2003-2006, with exposure of up to CAD$2 billion if the same principles were to be applied in respect of subsequent years to 2017.

During the taxation years 2003-2006, Cameco Corporation ("Cameco") and its subsidiaries constituted one of the world's largest producers and suppliers of uranium. Uranium is bought and sold in an unregulated market, under bilateral contracts but it is not traded on a commodity exchange.

In the 1990's, the Russian government agreed to convert its weapons-grade uranium to UF6 which could be used in American light water nuclear reactors. Cameco saw an opportunity to structure its affairs to address the international business opportunity of buying and selling the Russian uranium as well as its own uranium.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

Cryptocurrency Held Through A Bare Trustee: Tax Treatment And The 2026 Reporting Obligations

If you hold cryptocurrency, NFTs or other blockchain assets in someone else’s wallet, or hold assets in your own wallet for someone else, the arrangement is very likely a bare trust. Until recently, that carried almost no compliance consequence. It now carries three reporting obligations to track: the T3 filing for 2026, the T1135, and the proposed Crypto-Asset Reporting Framework from 2027.
CanadaTax
Rotfleisch & Samulovitch P.C.
Rotfleisch & Samulovitch P.C.
Article

How To Appeal The Toronto Vacant Home (VHT) Tax: Here’s What One Landlord Did To Fight VHT Assessment

Since 2022, the City of Toronto has imposed an annual Vacant Home Tax (VHT) on residential units left unoccupied for more than six months of the year. For most owners the tax is an afterthought: file the annual declaration, confirm the unit was lived in, and move on. But when the City’s administrative process breaks down, an owner can find themselves fighting a five-figure tax bill over a unit they insist was never vacant at all.
CanadaTax
Rotfleisch & Samulovitch P.C.
Rotfleisch & Samulovitch P.C.
Article

Canadian Prime Minister Announces ‘Productivity Mega Deduction’

Canada's new Productivity Mega Deduction permanently provides immediate expensing for a wide range of depreciable property and Canadian development expenses, dramatically expanding the scope beyond the previously announced Productivity Super Deduction. The measure aims to reduce Canada's marginal effective tax rate on new business investment to 6.4%, positioning it as the lowest among major economies and less than half the U.S. rate.
CanadaTax
Osler, Hoskin & Harcourt LLP
Osler, Hoskin & Harcourt LLP
Article

Productivity Mega Deduction: Key Tax Measures Announced At The Canada Investment Summit

Canada has introduced a permanent Productivity Mega Deduction allowing immediate expensing of up to 100% of eligible capital property costs and Canadian development expenses acquired after September 15, 2026. This measure aims to boost business investment and strengthen Canada's tax competitiveness by expanding immediate expensing eligibility from 15% to approximately two-thirds of capital investments, while reducing the country's marginal effective tax rate to 6.4%.
CanadaTax
McCarthy Tétrault
McCarthy Tétrault
Article

Plaintiffs Awarded A Total Of $800,000 In Damages For Defamation (Murdy v. Barrette)

A Canadian court awarded $800,000 in damages to a couple defamed by serious false allegations of sexual assault and criminal misconduct spread through social media. The case examines how factors like the severity of accusations, use of social media platforms, and a defendant's failure to mount a defense can dramatically escalate defamation damages beyond typical awards.
CanadaLitigation, Mediation & Arbitration
Gardiner Roberts LLP
Gardiner Roberts LLP
Article

Lights, Camera Infractions: A Review Of Ontario’s Automatic Enforcement System Offence Regime, The Risks To Commercial Vehicle Carriers And How Operators Can Protect Themselves

Ontario's automatic enforcement system (AES) offences, captured by red light cameras and similar technology, pose significant regulatory risks to commercial vehicle carriers. These offences carry the maximum 5 CVOR penalty points—equivalent to impaired driving or criminal negligence—yet are nearly impossible to defend or resolve through plea negotiations.
CanadaTransport
Gardiner Roberts LLP
Gardiner Roberts LLP
Article

Honest Belief No Defence To Defamatory Tweet About MP (Maggi v. Smith)

A recent Ontario court decision examines whether sincere belief in serious allegations can protect speakers from defamation liability when making accusations about public figures on social media. The case arose from posts alleging that a lawyer and Member of Parliament intimidated voters during a political nomination contest, raising important questions about the balance between free expression and reputation protection in political discourse.
CanadaLitigation, Mediation & Arbitration
Gardiner Roberts LLP
Gardiner Roberts LLP
Article

No Charter Right To Bicycle Lanes (Cycle Toronto v. Ontario (Attorney General))

The Ontario Court of Appeal has overturned a lower court ruling that found the provincial government's legislation to remove bicycle lanes from major Toronto streets unconstitutional. The decision addresses fundamental questions about the separation of powers between courts and legislatures, and whether the Canadian Charter of Rights and Freedoms creates positive obligations for governments to maintain infrastructure like bicycle lanes.
CanadaGovernment, Public Sector
Gardiner Roberts LLP
Gardiner Roberts LLP
Article

Lawyer Receives 6-Month Suspension For Misuse Of Artificial Intelligence (Law Society Of Ontario v. Lee)

The misuse of artificial intelligence by litigants and lawyers continues to be alarming. Although it is well-documented that generative artificial intelligence platforms have a tendency to produce inaccurate answers to legal questions, and, moreover, to produce output which references non-existing cases or which inaccurately portrays legal propositions in existing cases, these tools continue to be used recklessly.
CanadaCriminal Law
Gardiner Roberts LLP
Gardiner Roberts LLP