Patrick Marley

Supreme Court releases Alta Energy decision: taxpayer wins, application of GAAR to tax treaties clarified

Earlier today, the Supreme Court of Canada released its decision in Canada v. Alta Energy Luxembourg S.A.R.L., 2021 SCC 49.

136 countries agree to OECD/G20 Inclusive Framework’s two-pillar solution to international tax reform

Last week, 136 countries, including Canada and the United States, announced that they have agreed to the OECD/G20 Inclusive Framework’s two-pillar...

OECD/G20 Inclusive Framework reaches high-level agreement on two-pillar approach to international tax reform

In their Osler Update, authors Patrick Marley, Peter Macdonald, Kaitlin Gray and Taylor Cao comment on the statement by the OECD/G20 Inclusive...

Exchangeable share structures – an overview

Exchangeable share structures have been a fixture in structuring cross-border share exchange mergers and acquisitions involving Canadian corporations...

G7 Finance Ministers back international tax reform (Pillar One and Pillar Two), including introducing a global minimum tax of at least 15%

On June 5, 2021, the Finance Ministers from the G7 group of leading economies (including Canada) committed to the principal design elements for the...

Continued uncertainty following recent CRA position on Tax Treaty anti-avoidance rule

The most significant treaty modification implemented through the MLI was the addition of a broad anti-avoidance rule known as the principal purpose...

Osler submission on the OECD Pillar One and Pillar Two Blueprints

Earlier in 2020, the OECD published blueprint reports on Pillar One and Pillar Two and launched a public consultation process on its two-pillar...

COVID-19 tax measures and proposed international tax reform

Two significant tax developments in 2020 were Canada’s measures in response to COVID-19 and Canada’s participation with the OECD’s pursuit of...

OECD releases blueprint reports on international tax reform (Pillar One and Pillar Two) and launches public consultation

The OECD recently released blueprint reports on Pillar One and Pillar Two and launched a public consultation process on its two-pillar approach to...