Canadian pension funds welcome proposed tax changes on U.S. real estate investments
Canadian pension funds are welcoming proposed regulations from the U.S. Department of the Treasury that clarify the sweeping exemption from U.S. tax on real estate available to qualified foreign pension funds. “The previous regulatory framework reduced our demand for real estate in the U.S. and, as importantly, increased the cost and complexity of our structuring,” says […]
FP Dealmakers: After a tough first half, Bay Street bets on low interest rates driving more deals
Mining was a bright spot, but trade tensions and prospects of higher interest rates sucked the life out of deal flow in the first half of 2019 Bay Street’s top dealmakers blamed trade headwinds and prospects of higher interest rates for disappointing issuer activity in the first half of the year, but expect the outlook […]
Trade’s New Realities
If it feels like the tariff and trade rules are changing every day, it’s because they are For lawyers working in international trade law – not to mention their clients – it’s a strange new world indeed. “We’ve been working forever in an atmosphere of liberal trade, and we’ve never seen anything like the current […]
Understanding the New IP Laws
Between the USMCA, the updated Patent Act and the newly written Trademarks Act, lots has changed When and if the United States-Mexico-Canada Agreement (USMCA) is ratified by all parties, US attorneys and in-house counsel seeking to prosecute or enforce their clients’ intellectual property rights in Canada will notice its impact immediately. The agreement, which is […]
Merger challenge shows Competition Bureau focus on digital economy
Canada’s new Commissioner of Competition, Matthew Boswell, appointed just four months ago, has taken little time to make his mark as a man of his word. By initiating the first contested merger challenge since 2015, the first merger challenge ever involving software companies, the first involving a private equity company, and a rare challenge to […]
SCC decision will make it harder for tax evasion across provincial borders
The Supreme Court of Canada’s June judgment in 1068754 Alberta Ltd. v. Québec (Agence de Revenue) means that tax evaders will have no more luck hiding their assets extra-provincially than they currently do internationally. “This was an extraordinary 9-0 decision ensuring tax authorities that they will be able to get information out of any Canadian province just […]
SNC-Lavalin affair: Jobs over democracy
The “public interest,” it turns out, can be a real threat to democracy. It is, after all, the catchphrase that Prime Minister Justin Trudeau used to justify his contravention of the Conflict of Interest Act by pressuring former Justice Minister Jody Wilson-Raybould to negotiate a deferred prosecution agreement with SNC-Lavalin. The PM’s spin on the whole thing […]
Competition Bureau’s Call for Intel on Anti-Competitive Conduct in Digital Economy Raises Eyebrows
In a general sense, what the Bureau wants to know is whether the characteristics of certain digital markets favour concentration — a process called ‘tipping’ The Competition Bureau’s recent call to Canadians to flag anti-competitive conduct in the digital economy is raising eyebrows among industry professionals. Certainly, the Bureau’s consultation seems far more concrete than […]
A New Tax Law Could Spell Trouble for Safe Havens and Shell Companies — and it’s Already on the CRA’s Radar
The new law has set its sights on holding or shell companies set up principally to take advantage of a double taxation treaty Foreigners looking to Canada as a tax haven and Canadians seeking havens abroad will have to deal with a whole new set of rules when the Organisation for Economic Co-operation and Development’s Multilateral Instrument […]
Scheer’s Call for SNC Lavalin Inquiry During Election Dangerous Precedent
It may just be the brouhaha over Andrew Scheer’s dual citizenship that made me link Donald Trump’s vow to “jail Hillary” and “lock her up” with the Conservative leader’s pledge — in the middle of an election campaign, no less — to launch a judicial inquiry into Justin Trudeau’s conduct in the SNC Lavalin scandal. […]