Peter Macdonald Peter Macdonald

Department of Finance releases consultation paper proposing amendments to Canada’s transfer pricing regime

On June 6, the Canadian Department of Finance released a consultation paper proposing amendments to Canada’s transfer pricing regime and opened a...

Canadian anti-hybrid tax legislation released in draft

On April 29, 2022, the Department of Finance released the first of two packages of draft legislation to implement its proposals to eliminate the tax...

Economic and Fiscal Update 2021

The 2021 Economic and Fiscal Update sets out measures adopted and proposed to address the pandemic and support Canada’s economic recovery.

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...

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...

Supreme Court denies Crown’s request for leave to appeal Cameco transfer pricing decision

On February 18, 2021, the Supreme Court of Canada declined the Crown’s application seeking leave to appeal the June 2020 decision of the Federal...

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...