Patrick Marley

Published Work

Patrick is a contributing editor for Tax Management Business Operations in Canada, and is a regular contributor to Tax Management International Journal. Other publications include:

• Osler submission to OECD advocates for narrow application of Global Anti-Base Erosion Proposal (with K. Gray, T. Cao and K. Hawkins-Schluz), Osler Update, December 3, 2019
• Osler submission to OECD on Public Consultation Document for “Unified Approach” under Pillar One (with K. Gray, T. Cao and K. Hawkins-Schulz), November 11, 2019
• Unilateral or Unified:  Canada’s Approach to Taxing Digital Services, Tax Management International Journal (with K. Gray, T. Cao, and K. Hawkins-Schulz), November, 8, 2019
• OECD proposes significant international tax changes that will impact multinationals, Osler Update (with K. Gray and T. Cao), October 9, 2019

• CRA’s Interpretation of OECD Transfer Pricing Guidelines Appears Inconsistent with Canadian Law – Tax Management International Journal, October 12, 2018
• Canadian Royalty Payments to Non-Residents, Bloomberg BNA – Tax Management International Journal (with E. Gilmour), October 13, 2017
• International Tax Issues in Mergers and Acquisitions, ABA 2017 Section of International Law Spring Conference – Washington (with R. Misey, H. Knott, and P. Fuller), April 28, 2017
• OECD’s Multilateral Instrument for the Implementation of Tax Treaty-Related BEPS Measures, IFA 2017 International Tax Conference, April 25, 2017
• Are Private Equity Funds and Their Investment Entities Entitled to Tax Treaty Benefits? Tax Management International Journal – Bloomberg BNA, February 10, 2017
• OECD’s MLI: Will tax treaty benefits apply to private equity investors? Article for the PE Hub Network, January 24, 2017
• Are private equity and other collective investors entitled to tax treaty benefits? Osler Update, January, 2017
• Supreme Court of Canada clarifies the remedy of rectification in Canadian tax cases, Osler Update, December 12, 2016
• Significant tax treaty changes proposed in multilateral convention, Osler Update, November, 2016
• Canada-U.S. Investment – Canadian Tax Perspective “Acquiring a Canadian Corporation:  Canadian Tax Considerations”, Tax Management International Journal Article (with David Wilson), November 2016
• BEPS:  Another Year Older and Another Year Wiser, Bloomberg BNA:  2nd Annual International Tax Conference – Canada and Beyond, August 31, 2016
• Cross-Border IP Planning Post-BEPS, IFA International Tax Conference – Montreal, May 26 & 27, 2016
• Taxpayer wins interest deductibility case at Federal Court of Appeal:  The TDL Group Co. v. The Queen, 2016 FCA 67, Osler Update, March, 2016
• International Tax Planning for Canadians in a World of Changing Rules – What International Tax Reforms Could/Should Canada Consider? Canadian Tax Foundation Presentation with V. Sider, P. Halvorson and L. Chapman, February 9, 2016
• BEPS recommendations could significantly affect cross-border trade, Osler Update, December, 2015
• Saving the Planet (and Taxes) Accessing Green Energy Incentives, ABA Section of International Law – 2015 Fall Meeting, October 20-24, 2015
• International Tax Reform 2015-BEPS Final Reports, Osler Update, October, 2015
• Treaty Shopping – OECD Releases Revised Discussion Draft on BEPS Action 6, Osler Update, May, 2015
• From Theory to Practice:  Practical Consequences of BEPS in Cross-Border Deals, ABA Section of International Law 2015 Spring Meeting, May 2015
• International Tax Update – OECD/G20 BEPS Project, Tax Executives Institute, March 2015.
• BEPS Symposium:A Canadian Perspective, IFA/CTF, February 2015.
• Cross Border Cash Pooling Arrangements Involving Canadian Subsidiaries:  A Technical Minefield, Tax Management International Journal, June 13, 2014
• Impact of BEPS Report and Other Changes on Existing Structures and Proposed Commercial Transactions, IBA/CIOT Conference, February 2014
• Treaty Shopping Review, Canadian Tax Foundation Conference, November 2013
• International Highlights in Canada’s 2013 Budget, Tax Notes International, Volume 70, Number 1, April 1, 2013
• A Review of Foreign Affiliate Reorganization Rules After Recent Amendments, Canadian Tax Foundation Conference, November 2012
• Canada Approves New Foreign Affiliate Dumping Rules, Tax Notes International Vol. 68, Number 6, November 12, 2012
• International Investment Structures for Investment into Latin America, 2012 Fall Meeting Section of International Law, ABA, October 18, 2012
• Foreign Affiliate Proposals, International Fiscal Association, Canadian Branch Seminar, May, 2012
• Adverse Canada-U.S. Tax Treaty Hybrid Entity Rules Coming into Effect January 1, 2010, Osler Update, November 25, 2009
• Limitation on Benefits: Canadian Interpretation, Tax Management International Journal (Vol. 38, No. 10) October 9, 2009
• The Taxation of Mergers and Acquisitions in Canada, IFA – Bulletin for International Taxation August/September 2009 (IBFD)