Northleaf Capital Partners

Acted for Northleaf Capital Partners in connection with the restructuring of a previously formed evergreen credit fund established for two pension plan investors of Northleaf Capital Partners to facilitate the parties' commercial objectives in light of complex pension regulatory, tax and other challenges.

Northleaf Capital Partners

Acted for Northleaf Capital Partners in connection with the formation of an innovative evergreen opportunistic credit fund for a non-taxable US foundation.

The Cadillac Fairview Corporation Limited

Acted for The Cadillac Fairview Corporation Limited in (i) its C$295.35 million acquisition of an undivided 50% interest in the Fairview Pointe-Claire shopping centre located in Pointe-Claire, Québec, and its adjacent lands, from Ivanhoe Cambridge, and (ii) its C$232 million sale of an undivided 50% interest in the Galeries d'Anjou shopping centre located in Montréal to Ivanhoe Cambridge. Following the transaction, The Cadillac Fairview Corporation Limited became, directly or indirectly through affiliates, the sole owner of the Fairview Pointe-Claire shopping centre and its adjacent lands, whereas Ivanhoe Cambridge became, directly or indirectly through affiliates, the sole owner of the Galeries d'Anjou shopping centre. 

Premium Brands Holdings Corporation

Acted for Premium Brands Holdings Corporation in its groundbreaking partnership with a coalition of Mi'kmaq First Nations to jointly acquire Clearwater Seafoods Incorporated, Atlantic Canada's largest wild seafood company, for approximately $1 billion.

Sprott Resource Lending Corp.

Acted as tax counsel to Sprott Resource Lending Corp., as lead arranger for its resource lending investment funds, in the financing (of up to US$140 million) of Mudrick Capital Acquisition Corp.'s acquisition of Hycroft Mining Corp., a world-class gold and silver producing operator located in Nevada. The financing comprised a senior credit facility and a net smelter royalty.

Northleaf Capital Partners

Acted for Northleaf Capital Partners in its strategic sale of a non-controlling interest to Mackenzie Financial Corporation, a subsidiary of IGM Financial Inc., and Great-West Lifeco Inc.

InstarAGF Asset Management Inc.

Acted for InstarAGF Asset Management Inc. in the formation of US$1.2-billion InstarAGF Essential Infrastructure Fund II, an infrastructure fund focused on investments in North America, with limited partners from Canada, U.S., Europe and Asia.

Sprott Resource Lending Corp.

Acted as tax counsel to Sprott Resource Lending Corp., as lead arranger for its resource lending investment funds, in the financing (of up to US$160 million) of Emerald Resources NL's Okvau Gold Project, which is expected to be the first modern large-scale gold project in Cambodia. The financing comprised a senior credit facility and gold price derivatives.

Healthcare of Ontario Pension Plan

Acted for Healthcare of Ontario Pension Plan on its minority equity investment in Herschel Supply Co., a design-driven global lifestyle brand.

Canadian Business Growth Fund

Acted for Canada's leading banks and insurance companies to form the Canadian Business Growth Fund, an independent evergreen fund with a national mandate to provide long-term patient, minority capital to entrepreneurs pursuing growth and expansion strategies.

Northleaf Capital Partners

Acted for Northleaf Capital Partners in connection with the establishment of a US$1.4-billion Northleaf global private credit program and Northleaf's related acquisition, through a new Northleaf-managed investment fund, of a 16% equity stake in Antares Holdings from CPPIB Credit Investments Inc.

InstarAGF Asset Management Inc.

Acted for InstarAGF Asset Management Inc. in connection with the formation of InstarAGF Essential Infrastructure Fund with total equity capital commitments of $740 million.

500 Startups

Acted for 500 Startups in the formation of its first Canadian venture capital seed fund.

Birch Hill Equity Partners

Acted for Birch Hill Equity Partners in connection with its acquisition of a majority stake in Cozzini Bros., an Illinois-based knife sharpening rental and exchange company.

Cadillac Fairview Corporation

Acted for Cadillac Fairview Corporation in the sale of a 50% non-managing interest in its Vancouver portfolio, including CF Pacific Centre and 12 office towers, to Ontario Pension Board and the Workplace Safety and Insurance Board.

Oxford Park Group

Acted for Oxford Park Group in the formation of PointNorth Capital LP, a fund that continued Oxford Park's strategy of making special situation investments.

Cadillac Fairview Corporation Limited

Acted for Cadillac Fairview Corporation Limited in connection with the sale of a 30% non-managing interest in the Toronto-Dominion Centre and a concurrent sale of 30% interest in an office development site at 16 York Street to the Ontario Pension Board.

Bentall Kennedy (Canada) Limited Partner

Acted for the Bentall Kennedy Group, a premier real estate investment management firm operating in Canada and the United States, in its acquisition by Sun Life Financial Inc. for a purchase price of $560 million.

Alfa S.A.B. de C.V.

Acted for Alfa S.A.B. de C.V. in connection with its proposed acquisition, with Harbour Energy Ltd., of all of the outstanding common shares of Pacific Rubiales Energy Corp. for an all-cash purchase price of approximately $1.7 billion, plus the assumption of approximately $5 billion in debt. The acquisition was structured as a plan of arrangement under the Business Corporations Act (British Columbia).

RBC Capital Markets Inc.

Acted for a syndicate of underwriters led by RBC Capital Markets in connection with Chesswood Group Limited's $32-million public offering and $6-million private placement of subscription receipts. The proceeds from the offerings were used to partially finance the purchase price for Chesswood's $64-million acquisition of Blue Chip Leasing Corporation and EcoHome Financial Inc.

Major shareholder of Porter Aviations Holdings Inc.

Acted for a major shareholder of Porter Aviation Holdings Inc. in the sale of the passenger terminal at Billy Bishop Toronto City Airport to Nieuport Aviation Infrastructure Partners, a consortium of Canadian and international infrastructure investors, including AGF Management Ltd.'s InstarAGF Asset Management Inc.

Temasek Holdings (Private) Limited

Acted for Temasek Holdings (Private) Limited in connection with its investment, together with CEF Holdings Limited, in Magris Resources Inc. to fund Magris' initial acquisition of Iamgold Corp's Niobec mine for approximately US$530 million.

Onex Corporation

Acted as Canadian counsel for Onex Partners in connection with the $775-million refinancing of JELD-WEN inc.'s existing indebtedness.

Onex Corporation

Acted as Canadian counsel for Onex Partners in the $715-million financing in connection with the acquisition of York Risk Services Group, Inc.

Fortis Inc.

Acted for Fortis Inc. in its $600-million bought deal public offering of Series M first preference shares, one of the largest preferred share offerings in Canadian history. The net proceeds were used to repay borrowings incurred to fund the US$2.5-billion cash purchase price paid to acquire UNS Energy Corporation, an Arizona-based utility engaged in the regulated electric generation and energy delivery business.

Canada Pension Plan Investment Board

Acted for the Canada Pension Plan Investment Board in connection with its joint venture with WAM Development Group and Walton Group of Companies to develop a 250-acre industrial site in northwest Edmonton, Alberta. CPPIB's initial equity commitment is approximately $200 million for phase one of the development, representing an 85% interest in the joint venture.

The Cadillac Fairview Corporation Limited

Acted for The Cadillac Fairview Corporation Limited in connection with its $650-million purchase of the Hudson's Bay downtown Toronto flagship retail complex and the Simpson's Tower located at 401 Bay Street. HBC will lease the entire retail and office complex back for a base term of 25 years with renewal options for a term of just under 50 years.

Diversified Global Asset Management Corporation

Acted for Diversified Global Asset Management Corporation, a global manager of hedge funds with more than $6.7 billion in managed and advised assets, in its acquisition by The Carlyle Group. 

National Bank Financial Inc. and RBC Capital Markets

Acted for a syndicate of underwriters co-led by National Bank Financial Inc. and RBC Capital Markets in connection with a shelf offering of convertible unsecured subordinated debentures of Chesswood Group Limited.

Cadillac Fairview Corporation Limited

Acted for The Cadillac Fairview Corporation Limited in connection with the full surrender by Sears Canada Inc. of its leases at four shopping centres, and the partial surrender by Sears of its lease at a fifth shopping centre, for a total consideration of $400 million.

Ontario Teachers' Pension Plan Board

Acted for Ontario Teachers' Pension Plan Board in connection with its US$500-million equity investment in Hudson's Bay Company to finance the acquisition by Hudson's Bay Company of Saks Incorporated in an all-cash transaction valued at approximately US$2.9 billion including debt, along with related governance and shareholder arrangements.

Canada Pension Plan Investment Board

Acted for the Canada Pension Plan Investment Board in connection with the sale to Ivanhoé Cambridge of a 50% interest in Carrefour de l'Estrie shopping centre located in Sherbrooke, Québec, which is the largest shopping centre in Québec's Eastern Townships region, and the resulting joint venture.

Canada Pension Plan Investment Board

Acted for the Canada Pension Plan Investment Board in connection with a 50/50 Canadian retail joint venture with Oxford Properties Group. As part of the transaction, CPPIB acquired a 50% interest in the approximately 1 million square foot Upper Canada Mall, in Ontario, from Oxford Properties Group, and Oxford Properties Group acquired a 50% interest in the 1.5 million square foot Les Galeries de la Capitale shopping centre, in Québec, from CPPIB.

The Cadillac Fairview Corporation Limited

Acted for The Cadillac Fairview Corporation Limited in connection with its US$150 million investment in Terranum Corporate Properties, a Colombian commercial property development business.

RX Gold & Silver Inc.

Acted for RX Gold & Silver Inc. on its share-exchange merger with U.S. Silver Corporation to create U.S. Silver & Gold Inc., a North American focused precious metals producer with a market capitalization of approximately $140 million. The combination was effected by way of two simultaneous plans of arrangement through which the new company acquired both RX Gold & Silver and U.S. Silver, with the RX Gold & Silver shareholders holding 30%, and the U.S. Silver shareholders holding 70%, of the new company.

KGHM Polska Miedz S.A.

Acted for KGHM Polska Miedz S.A., one of Poland's leading companies and Europe's largest copper miner, in its $2.87-billion acquisition of Quadra FNX Mining Ltd.  At the time of closing, this was the largest ever foreign acquisition by a Polish company.

The Cadillac Fairview Corporation Limited

Acted as Canadian counsel to The Cadillac Fairview Corporation Limited and its affiliates in connection with investments in Brazil, including the $500-million investment in Multiplan Empreendimentos Imobiliários S.A., one of the leading developers, owners and operators of shopping centres in Brazil.

Global Railway Industries Ltd.

Acted for Global Railway Industries Ltd. in the sale of its operating subsidiary, CAD Railway Industries Ltd.

EdgeStone Capital Partners

Acted for EdgeStone Capital Partners in connection with the US$415 million sale of Continental Alloys & Services, Inc. to Reliance Steel & Aluminum Co.

Fronteer Gold Inc.

Acted for Fronteer Gold Inc. in its $2.3-billion acquisition by Newmont Mining Corporation (now known as Newmont Goldcorp Corporation). The transaction was structured as a plan of arrangement providing for cash consideration and the spin off of shares of Pilot Gold Inc., a new TSX-listed company holding exploration assets, to the former shareholders of Fronteer Gold.

Ventana Gold Corp.

Acted for Ventana Gold Corp. in connection with the unsolicited $1.5-billion takeover bid by an affiliate of Eike Batista for all of the outstanding Ventana shares, which ultimately resulted in a supported transaction at a higher price.

Onex Corporation

Acted for Onex Corporation in connection with a $2.4-billion refinancing of its U.S. subsidiary Carestream Health Inc., which funded a $725 million distribution by Carestream to its shareholders.

Rogers Sugar Income Fund

Acted for Rogers Sugar Income Fund and Rogers Sugar Inc. in the conversion of Rogers Sugar Income Fund to a corporate structure by way of plan of arrangement.

Xstrata Canada Corporation

Acted for Xstrata Canada Corporation in its proposed acquisition of Noranda Income Fund.

Barzel Industries Canada Inc.

Acted for Barzel Industries Canada Inc. (formerly Novamerican Steel) in its cross-border restructuring proceedings involving independent proceedings under the Companies' Creditors Arrangement Act run in parallel concert with U.S. Chapter 11 proceedings for the U.S. parent company and U.S. subsidiaries and implementing a cross-border "stalking horse" sale agreement, cross-border bidding and auction process and closing of such sale within 65 days of the initial filing.

BHP Billiton

Acted for BHP Billiton in connection with its $274-million all-cash acquisition of Anglo Potash Ltd. by way of a plan of arrangement.

Reuters Group PLC

Acted as Canadian counsel for Reuters Group PLC in its dual-listed company merger with The Thomson Corporation to create Thomson-Reuters in a transaction valued at US$17.6 billion, creating the first Canadian dual-listed company structure.

TPG Partners V LP

Acted for TPG Partners V LP in connection with its acquisition of Axcan Pharma Inc. in an all-cash transaction valued at US$1.3 billion.

Barzel Industries Inc.

Acted for Barzel Industries Inc. (formerly Symmetry Holdings Inc.) in its acquisition of Novamerican Steel Inc. for a purchase price of US$585 million.

Edgestone Capital Equity Fund III, L.P.

Acted for private equity fund EdgeStone Capital Equity Fund III, L.P. in its acquisition and subsequent divestiture of an equity interest in Motion Picture Distribution LP, the former motion picture distribution arm of Alliance Atlantis Communications Inc.

EdgeStone Capital Equity Fund III, LP

Acted for private equity fund EdgeStone Capital Equity Fund III, LP in its $70-million negotiated takeover bid for Stephenson's Rental Services Income Fund.

Dynatec Corporation

Acted for the Special Committee of Dynatec Corporation in the negotiated sale of Dynatec to Sherritt International Corporation by way of a share exchange plan of arrangement in a transaction valued at $1.6 billion.

Global Alumina Corporation

Acted for Global Alumina Corporation in connection with the formation of a joint venture with BHP Billiton, Dubai Aluminium Company and Mudabala Development Company for the development of an alumina mining and refinery project in the Republic of Guinea.

Onex Corporation

Acted for Onex Corporation on Canadian tax matters in connection with the attempted takeover of Australia's largest airline carrier, Qantas, by a consortium including Onex in a transaction valued at $10.2 billion that would have given Onex 12.5% of the airline.

Agnico Eagle Mines Limited

Acted for Agnico Eagle Mines Limited in its negotiated share exchange takeover bid for Cumberland Resources Ltd. valued at $710 million.

Onex Corporation

Acted for Onex Corporation on financing matters in connection with Onex's acquisition of Eastman Kodak Company's Health Group, renamed Carestream Health, Inc., in a transaction valued at US$2.35 billion.

Xstrata plc

Acted for Xstrata plc in connection with its 144A US$500 million offering of 6.9% notes due 2037. The notes were offered by Xstrata Finance (Canada) Ltd., a subsidiary of Xstrata and guaranteed by Xstrata and certain of its subsidiaries.

Xstrata plc

Acted for Xstrata plc in connection with the establishment of its US$6-billion Euro Medium Term Note Programme.

Trizec Canada Inc. and Trizec Properties Inc.

Acted for Trizec Canada Inc. and as Canadian counsel to Trizec Properties, Inc., one of the largest publicly traded REITs in the United States (and 38% owned by Trizec Canada), in their strategic auction, ultimately culminating in Brookfield Properties Corporation acquiring Trizec Canada in an all-cash plan of arrangement and Trizec Properties in a parallel US cash-out merger. The combined transaction was valued at US$8.9 billion.

EdgeStone Capital Partners

Acted for private equity firm EdgeStone Capital Partners in the sale of the firm to GMP Capital Trust.

Tim Hortons Inc.

Acted as special counsel to Tim Hortons Inc. in its $900 million initial public offering by Wendy's International, Inc. on the TSX in Canada and the NYSE in the United States.

TD Capital Private Equity Investors

Acted for TD Capital Private Equity Investors in connection with the formation of a fund to invest $400 million on behalf of Canada Pension Plan Investment Board in mid-sized Canadian buyout funds and Canadian venture capital funds.

Xstrata plc

Acted for Xstrata plc in connection with its US$2.25-billion 144A note offering.

Tim Hortons Inc.

Acted for Tim Hortons Inc. in its spin-off from Wendy's International, Inc. valued at $4.6 billion.

EdgeStone Capital Partners

Acted for EdgeStone Capital Partners in the formation of EdgeStone Capital Equity Fund III, an $800-million private equity fund.

Global Alumina Corporation

Acted for Global Alumina Corporation in connection with the establishment of interim credit facilities in the amount of US$100 million.

EdgeStone Capital Equity Fund III LP

Acted for private equity fund EdgeStone Capital Equity Fund III LP in its acquisition, along with its co-investors including Canada Pension Plan Investment Board, of a 50% interest in Continental Alloys & Services, a Houston-based global manufacturer and distributor of bar and tubular products for the oilfield service industry.

ONCAP L.P.

Acted for Oncap in connection with the formation of Oncap II, a $575-million private equity fund focused on investing in small and medium-sized businesses in North America. Oncap is the private, mid-market private equity fund of Onex Corporation.

BMO Nesbitt Burns and TD Securities Inc.

Acted for two separate syndicates of underwriters co-led in Canada by BMO Nesbitt Burns and TD Securities Inc. and in the U.S. by J.P. Morgan Securities Inc. and Morgan Stanley & Co. Incorporated in private placement offerings by Molson Coors Capital Finance ULC of $900 million 5.00% senior notes due 2015 in Canada and US$300 million 4.85% senior notes due 2010 in the United States. The senior notes issued in Canada were subsequently exchanged for 5.00% senior notes due 2015 of Molson Coors Capital Finance qualified by a Canadian prospectus filed under the northbound multi-jurisdictional disclosure system.

Shoreview Capital Partners

Acted as Canadian counsel to Shoreview Capital Partners on its acquisition of Paradigm Electronics Inc. in a transaction valued at approximately US$60 million.

Birch Hill Equity Partners

Acted for Birch Hill Equity Partners in connection with the formation of Birch Hill Equity Partners III, LP, an $850-million private equity fund.

Onex Corporation

Acted for Onex Corporation, which owned Mid-Western Aircraft Systems, which acquired the Wichita/Tulsa divisions of Boeing Commercial Airplanes in a transaction valued at $1.5 billion.

Bain Capital

Acted for an affiliate of Bain Capital in the sale of its interests in Advertising Directory Solutions Inc. for a purchase price of approximately $2.55 billion.

Viking Air Limited

Acted for Viking Air Limited in connection with obtaining exclusive rights to manufacture and distribute spare parts for the de Havilland fleet of heritage aircraft from Bombardier Inc. with respect to the acquisition of certain assets of Bombardier's Commercial Service Centre.

Rogers Sugar Income Fund

Acted for Rogers Sugar Income Fund in its public offering of $50 million principal amount of 6.00% convertible unsecured subordinated debentures.

Bulletin

Federal Budget 2022: Tax Highlights

Apr. 08, 2022 - On April 7, 2022 (Budget Day), the Honourable Chrystia Freeland, Deputy Prime Minister of Canada and Minister of Finance, delivered the Liberal Party’s federal budget (Budget 2022), the second budget since the start of the COVID-19 pandemic. As part of the Trudeau government’s plan to “grow our...

Bulletin

Canadian Tax Laws: A Review of 2019 and a Look Ahead to 2020

Jan. 30, 2020 - Each year at this time we look back at some of the more significant income tax developments in Canada affecting domestic and international business over the past year and look ahead to possible Canadian tax developments in the coming year. Review of Canadian Tax Developments in 2019 Tax...

Bulletin

Draft Legislation on the Taxation of Stock Options

June 19, 2019 - The federal government has released much anticipated draft legislation proposing changes to the rules relating to the taxation of stock options. The legislative proposals are expected to come into force on January 1, 2020, and to apply to option agreements entered into after 2019. The release, on...

Bulletin

Canadian and U.S. Tax Laws: A Review of 2018 and a Look Ahead to 2019

Jan. 31, 2019 - In our annual Tax Review and Outlook report, we look back at significant developments in the Canadian and U.S. tax landscapes in 2018 and offer our predictions on what to expect in 2019. Key Canadian Developments in 2018 Budget 2018 scaled back controversial initiative on taxation of...

Bulletin

Canadian Tax Laws: A Review of 2018 and a Look Ahead to 2019

Jan. 31, 2019 - Each year at this time we offer a look back at some of the more significant income tax developments in Canada affecting domestic and international business over the past year and a look ahead to possible Canadian tax developments in the coming year. Legislative Developments in 2018

Bulletin

Tax Court Finds That Broker Fees on a Private Company Sale Were GST/HST-Taxable

May 10, 2018 - The Tax Court of Canada recently released its decision in Barr v. The Queen, 2018 TCC 86, which considered whether share-sale commissions were exempt from HST. The taxpayer was the sole shareholder of a Canadian company. He had retained two brokers for the sale of his company or its...

Bulletin

2018 Federal Budget: Tax Highlights

Feb. 27, 2018 - As anticipated, today’s federal budget (Budget 2018) focuses on a few targeted areas, including the taxation of passive investments made by private corporations, and does not contain any measures in response to the enactment of tax reform in the United States or relating to the OECD BEPS...

In the News

Ian Crosbie Reacts to Federal Court of Appeal Decision in Lawyer’s Daily

Feb. 23, 2018 - In a recent article (available to subscribers) published in The Lawyer’s Daily, Davies partner Ian Crosbie commented on the decision of the Federal Court of Appeal (FCA) in Canada v. Oxford Properties Group Inc. The case centred on a number of transactions undertaken by Oxford...

Bulletin

U.S. Tax Laws: A Review of 2017 and a Look Ahead to 2018

Jan. 11, 2018 - Each year at this time, we offer a look back at some of the more significant income tax developments in the United States affecting domestic and international business over the past year and a look ahead to possible U.S. tax developments in the coming year. Tax Developments in 2017 As we...

Bulletin

Canadian Tax Laws: A Review of 2017 and a Look Ahead to 2018

Jan. 11, 2018 - Each year at this time we offer a look back at some of the more significant income tax developments in Canada affecting domestic and international business over the past year and a look ahead to possible Canadian tax developments in the coming year. Developments in 2017 1....

Bulletin

Department of Finance Releases Revised Income Splitting Rules

Dec. 13, 2017 - Earlier this year, the Department of Finance released a set of far-reaching proposals affecting the taxation of private businesses and their shareholders. Only Rip Van Winkle missed the firestorm reaction to these proposals from a broad range of affected parties. Ultimately, the Government...

Bulletin

2017 Federal Budget: Tax Highlights

Mar. 22, 2017 - The Liberal government’s second budget (Budget 2017) comes during a period of exceptional global political and economic uncertainty. Of particular importance from a Canadian economic and tax policy perspective is the uncertainty about how the Trump administration’s agenda will unfold in the coming...

Bulletin

Canadian and U.S. Tax Laws: A Review of 2016 and a Look Ahead to 2017

Jan. 13, 2017 - The year 2016 was eventful from a Canadian tax perspective, with the current Liberal government introducing its first federal budget and important judicial developments that included two decisions in tax cases by the Supreme Court of Canada. Conversely, while U.S. tax developments in 2016 were...

Bulletin

The Federal Court of Appeal Permits Use of Mark-To-Market Tax Accounting

June 24, 2016 - The Federal Court of Appeal has held in the Kruger Inc. v. Canada decision published yesterday, that Kruger Inc. was entitled to use the mark-to-market method in computing its income for federal income tax purposes.   As a result, for income tax purposes it was entitled to recognize an...

Bulletin

To Go or Not to Go? The 30% Rule for Canadian Pension Funds

June 06, 2016 - Canadian pension funds and their subsidiaries are subject to a rule that prohibits them from investing in shares of a corporation having more than 30% of the votes for the election of directors, except in the case of qualifying real estate, resource and investment subsidiaries (the so-called 30%...

Bulletin

2016 Federal Budget: Tax Highlights

Mar. 22, 2016 - The new Liberal government’s first budget (Budget 2016) has been the subject of anticipation and speculation, much of it apprehensive. Unusually, Budget 2016 is noteworthy for what it does not contain. Budget 2016 does not introduce changes to increase the tax rate on employee stock...

Bulletin

Recent Developments in Ontario Real Estate

Feb. 26, 2016 - Ontario Court of Appeal Rules on Assignment of Lease by Tenant The Ontario Court of Appeal recently released its decision in Hudson’s Bay Company v. OMERS Realty Corporation, a case that involved the assignment and sublease of the tenant’s interest in anchor tenant...

Bulletin

Canadian and U.S. Tax Laws: A Review of 2015 and a Look Ahead to 2016

Jan. 20, 2016 - Each year at this time, we offer a look back at some of the more significant business and international tax developments in Canada and the United States over the past year and a look ahead to possible Canadian and U.S. tax developments in the coming year. Canadian Tax Review and...

Bulletin

IRS Announces Expanded “No-Rule” Area for Spinoffs

Sept. 16, 2015 - On January 27, 2015, Yahoo Inc. announced its intention to seek an IRS private ruling that would confirm its view that the inclusion of a relatively small active business along with its stake in Alibaba Group Holding Ltd. would meet the “active business requirement” for...

Bulletin

2015 Federal Budget: Tax Highlights

Apr. 21, 2015 - As has been widely predicted, today’s federal budget (Budget 2015) delivered a handful of tax “goodies” in the lead-up to the coming election. It also includes a number of important proposed changes to the corporate tax rules. They are noteworthy, although not as...

Bulletin

Canadian and U.S. Tax Law: A Review of 2014 and a Look Forward to 2015

Jan. 13, 2015 - Each year at this time, we offer a look back at some of the more significant business and international tax developments in Canada and the United States over the past year and a look forward to possible Canadian and U.S. tax developments in the coming year. I. CANADIAN TAX REVIEW AND...