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Many firms and practitioners creating transfer-pricing documentation often attempt, as their primary goal, to avoid costly transfer pricing penalties. Subsection 247(3) of the Canadian Income Tax Act (the "Act") discusses the application of such a penalty.

In my 35+ years of experience, I have seen the tax world evolve quite a bit. It used to be that tax or trade lawyers were engaged very early on in most disputes. Usually at the time of audit.

In preparation for the upcoming proxy season, issuers should familiarize themselves with the Canadian proxy voting guidelines recently published by Institutional Shareholder Services Inc. (ISS) and Glass Lewis & Co.

In preparation for the upcoming proxy season, issuers should familiarize themselves with the Canadian proxy voting guidelines ...

Justice Farley of the Ontario Superior Court of Justice, Commercial List, (the "court") held that creditors are entitled to legally setoff post-filing claims against pre-filing claims in the context of a proceeding under the 'Companies Creditors Arrangement Act' ("CCAA").

In Harbert Distressed Investment Fund, LP v. General Chemical Canada Ltd. (2006) CarswellOnt. 4675 (Ont. Superior Court) an interim receiver applied to the Court for permission to distribute $3.7 million to the plaintiff secured creditor Harbert Distressed Investment Fund, LP ("Plaintiff").

On December 12, 2003, Prime Minister Paul Martin was sworn in as Canada's 21st Prime Minister. After taking his oath of office, Prime Minister Martin appointed his first Cabinet; and announced his plans to "change government", "build a twenty-first century economy" and "secure Canada's public health and safety.

On July 29, 2004, the Supreme Court of Canada released its decision in <I>Monsanto Canada Inc. v. Ontario (Superintendent of Financial Service)</I>. The decision creates an obligation for employers who have partially wound-up their defined benefit pension plans to distribute a proportional share of actuarial surplus in the plan as at the partial wind up date. This represents a significant shift in the timing of surplus distribution in Canada. Before the Monsanto case, no court&nbs

Donors and charities would be prudent to monitor these developments and obtain professional advice where necessary.

When most taxpayers receive a Notice of Assessment from the Canada Revenue Agency (CRA), they likely have the following concern: what did I do wrong?

Accounting involves communication and the use of language to convey business information. As with all languages, communication can create misunderstandings if one does not understand...

On October 16, 2009, the Canadian Securities Administrators (CSA), except the Autorité des marchés financiers and the New Brunswick Securities Commission, published for comment amendments (the Proposed Amendments) to National Instrument 81-106 “Investment Fund Continuous Disclosure” (the Instrument) and Companion Policy 81-106CP “Investment Fund Continuous Disclosure” (the Policy).

On June 26, 2023, the International Sustainability Standards Board (ISSB) released its inaugural standards which set out requirements for sustainability-related (IFRS S1) and climate-related (IFRS S2)...

As I write this article, Toronto is recovering from its biggest rainfall since Hurricane Hazel. Two weeks ago, downtown Calgary was affected by days of heavy rains following which the Bow River burst its banks. And while the initial focus should always be on the personal safety of those affected, in short order this focus will give way to dealing with the financial consequences of the events which have occurred.

In O'Brien v. Maxar Technologies Inc., Justice Akbarali declined to grant the plaintiffs' motion for leave to proceed with claims under section 138.3(1) of the Ontario Securities Act ("OSA")...