https://gowlingwlg.com/ecaapi/en-ca/rss/resource?service=TaxGowling WLG Resources RSS Feed37414936-fea7-4452-a4da-d9cb2e195737https://gowlingwlg.com/en-CA/insights-resources/client-work/2026/corporate-team-advises-systematic-growth-on-acquisition-of-4secureOur Corporate team has advised long-standing client Systematic Growth, via its Elvirian business, on the acquisition of software security specialist 4Secure, strengthening its portfolio of cybersecurity solutions for organisations operating across the defence, government and critical infrastructure sectors.Thu, 13 Aug 2026 00:00:00 Z6b007a25-6c59-414d-9e38-2465b5b0eef9https://gowlingwlg.com/en-CA/insights-resources/client-work/2026/corporate-team-advises-on-sale-of-jaltek-holdings-limited-to-norautron-asOur Corporate team has advised the shareholders of Jaltek Holdings Limited, a UK-based provider of advanced electronics manufacturing services, on a pre-sale reorganisation and subsequent sale to Norautron AS, supporting the group's continued international growth strategy.Mon, 10 Aug 2026 00:00:00 Zc2172b35-5513-4793-ae72-387d30af5cd4https://gowlingwlg.com/en-ca/insights-resources/articles/2026/ontario-superior-court-clarifies-bond-3-percent-premium-taxOntario insurers writing surety business may need to revisit how they report surety fee income following a Superior Court decision confirming that these fees fall within the province’s premium-tax regime.Wed, 05 Aug 2026 00:00:00 Z9c335604-675b-4210-8a11-451f47c50cfbhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2026/gowling-wlg-advises-manchester-super-giantsWe advised Manchester Super Giants on the acquisition of land adjacent to Emirates Old Trafford, supporting the development of a new high performance cricket centre. The transaction forms part of a wider investment in cricket infrastructure and player development.Tue, 28 Jul 2026 00:00:00 Z00ae3426-aa8d-4cb7-8709-8d287550484ehttps://gowlingwlg.com/en-ca/insights-resources/articles/2026/demerge-no-more-how-proposed-uk-tax-reformsThe government's proposed tax reforms could significantly restrict the availability of pre-sale demergers, removing a key structuring option for businesses. While statutory demerger rules may be relaxed, many transactions could face reduced flexibility and less commercially aligned outcomes.Wed, 15 Jul 2026 00:00:00 Zae82833b-6bac-48b8-bbef-231c37a4e81ahttps://gowlingwlg.com/en-ca/insights-resources/client-work/2026/real-estate-team-advises-ridgeback-and-morgan-stanley-on-1-billion-private-rented-sector-acquisitionOur Real Estate team has advised Ridgeback Group and Morgan Stanley Real Estate Investing on the acquisition of London & Quadrant Housing Trust (L&Q) private rented sector business, Metra Living, for a total enterprise value of £1.045 billion.Tue, 23 Jun 2026 00:00:00 Zc727d969-f398-4284-a72e-6ca8525c2369https://gowlingwlg.com/en-ca/insights-resources/articles/2026/ontario-expands-scope-of-buyers-entitled-to-hst-relief-on-new-homesIn the lead-up to the recently released Ontario Budget 2026, the Ontario Government announced its intention to fully rebate the 13% HST on sales of new detached and semi-detached houses, condominium units, townhouses and rowhouses, purchased as a primary place of residence or for long-term rental.Mon, 13 Apr 2026 00:00:00 Zca86d5a2-ae60-4a3f-a34a-fd024d5af4a9https://gowlingwlg.com/en-ca/insights-resources/client-work/2026/gowling-wlg-advised-mcintyre-partners-on-acerta-energyGowling WLG advised McIntyre Partners on Acerta Energy Ltd.’s acquisition of operated light oil and gas assets in central Alberta’s Cardium area from Hawthorne Energy.Fri, 10 Apr 2026 00:00:00 Z7c8d63e4-9db8-4de3-b7a1-49ac90c1238ahttps://gowlingwlg.com/en-ca/insights-resources/client-work/2026/real-estate-team-advises-lincoln-mgtOur real estate team advised Lincoln MGT on the £200 million plus sale of Ebb & Flow, a 598‑home build‑to‑rent scheme in Reading, to Pension Insurance Corporation, one of the UK's largest recent BTR deals. Read the full announcement.Wed, 08 Apr 2026 00:00:00 Z1a509035-fc5e-4ca7-8b97-5e3e72aef408https://gowlingwlg.com/en-ca/insights-resources/client-work/2026/cross-firm-team-advises-padlock-euro-storage-fund-i-on-major-portfolio-saleA cross firm team at Gowling WLG has advised Padlock Euro Storage Fund I on a major portfolio sale.Tue, 24 Mar 2026 00:00:00 Z96a296c2-aa8b-4038-8d53-f900cd9b8d99https://gowlingwlg.com/en-ca/insights-resources/client-work/2026/cross-firm-team-advises-hyde-groupWe advised Hyde Group on its long‑term investment partnership with Legal &amp; General to scale affordable housing delivery across the UK. Our teams provided integrated corporate, finance and regulatory support to structure and document the new joint venture.Mon, 23 Mar 2026 00:00:00 Zfc21fdd9-698b-406c-864b-3454533c969dhttps://gowlingwlg.com/en-CA/insights-resources/articles/2026/finance-consults-on-adding-domestic-content-to-clean-economy-investment-tax-creditsAs first announced in Budget 2025, the Department of Finance has launched consultations on whether to introduce a content requirement under two of Canada’s clean economy investment tax credits (ITCs). We cover the questions the consultation poses ahead of the March 13 deadline.Tue, 24 Feb 2026 00:00:00 Z978765bb-6923-4f45-bd87-b325d9dc18f1https://gowlingwlg.com/en-CA/insights-resources/client-work/2026/financial-services-and-funds-team-advises-pacific-asset-managementOur Financial Services and Funds team advised on the £212 million transaction between Pacific Asset Management and Pinnacle Investment Management. The deal was led by Kris Rogers with specialist support across Funds, Tax and Banking.Thu, 05 Feb 2026 00:00:00 Z89cc9593-b492-4ce9-beb9-d3fe4bab2bcfhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2026/qcp-quantum-capital-partners-supported-on-acquisition-financing-of-marley-deutschland-gmbhQCP Quantum Capital Partners has completed the financing of its acquisition of Marley Deutschland GmbH, positioning the German market leader for growth following its carve‑out and operational transformation.Tue, 20 Jan 2026 00:00:00 Za77d3a51-65e0-46f1-abf7-78963d594916https://gowlingwlg.com/en-ca/insights-resources/articles/2026/alberta-reshaping-electricity-system-for-data-centresDriven by explosive demand for AI, hyperscale computing and cloud storage, Alberta’s electricity system is fast becoming a key gatekeeper for data centre growth.Mon, 12 Jan 2026 00:00:00 Z85ab7cf3-c7be-4531-9f9c-f62d477e7381https://gowlingwlg.com/en-CA/insights-resources/articles/2026/canada-clean-economy-investment-tax-creditsCanada’s clean economy investment tax credits are moving from policy to practice, bringing significant opportunities alongside heightened compliance expectations.Mon, 12 Jan 2026 00:00:00 Z7b587b72-2b5f-4efb-96a8-f176b44fad41https://gowlingwlg.com/en-ca/insights-resources/articles/2026/cra-guidance-voluntary-disclosuresAfter years of tightening, the CRA has relaxed aspects of its Voluntary Disclosure Program, expanding relief for certain taxpayers.Wed, 07 Jan 2026 00:00:00 Z8bd563a9-e524-4be4-8a45-48ac2d2a2dcahttps://gowlingwlg.com/en-ca/insights-resources/articles/2025/budget-2025-proposal-to-stop-backdating-transfer-pricing-documentationCanada’s 2025 federal budget 2025 introduced long-anticipated amendments to Canada’s transfer pricing rules following a consultation process initiated in June 2023. These measures represent the most significant modernization of section 247 of the Income Tax Act since its introduction in 1998.Wed, 10 Dec 2025 00:00:00 Z495de19e-79c1-404d-a0e7-3cdd0ed20e4dhttps://gowlingwlg.com/en-ca/insights-resources/articles/2025/legislation-to-formally-repeal-the-canadian-dst-introducedBusinesses affected by Canada’s Digital Services Tax (DST) may finally see long-awaited relief. Newly tabled Bill C-15 would formally repeal the DST and require refunds of amounts already paid.Mon, 01 Dec 2025 00:00:00 Z99a11d9e-de6c-4901-b7f7-c450c4d3a6fchttps://gowlingwlg.com/en-ca/insights-resources/articles/2025/auditor-general-report-cra-challengesThe Auditor General’s review of the Canada Revenue Agency (CRA) contact centres highlights service gaps and oversight failures with direct implications for businesses, charities, not-for-profits, and individuals. This article outlines the key findings and what they mean for those navigating Canada’s tax system.Thu, 27 Nov 2025 00:00:00 Z53961856-f0f2-4d21-b368-808a9a10b319https://gowlingwlg.com/en-CA/insights-resources/client-work/2025/gowling-wlg-advised-aquanty-inc-in-acquisition-by-rocscienceOn November 26, 2025 , Rocscience completed the acquisition of Aquanty Inc., a Canadian water science and technology firm specialising in advanced hydrogeological modelling software and services.Thu, 27 Nov 2025 00:00:00 Z5aa65fec-889c-428c-947e-aba1bcbb533ehttps://gowlingwlg.com/en-ca/insights-resources/articles/2025/extension-home-buyer-rebate-ontario-hstThe Ontario Government has announced its intention to extend the Federal Government’s previously announced GST relief for first-time home buyers to the Ontario as part of the HST.Thu, 13 Nov 2025 00:00:00 Z353548e9-55cd-4bee-a2ae-680be59e62a0https://gowlingwlg.com/en-CA/insights-resources/articles/2025/clean-economy-investment-tax-credits-budget-2025Canada’s clean economy investment tax credits are reinforced with, proposed extensions, and targeted refinements announced in the latest federal updates. Our Tax Group examines what’s new in Budget 2025 and the 2024 Fall Economic Statement — and what these changes mean for businesses investing in clean technology, hydrogen, carbon capture and electricity.Thu, 13 Nov 2025 00:00:00 Z2f763d4d-915c-4715-9eef-80beb6c00a1chttps://gowlingwlg.com/en-ca/insights-resources/articles/2025/federal-budget-2025-investment-in-uncertain-timesOn November 4, 2025, the Government of Canada tabled Budget 2025, 18 months after the last Budget. In an era of economic and political uncertainty, Budget 2025 provides for significant increased spending on defence, housing and other areas, and projects a deficit of $78.3 billion for 2025-26, well in excess of last year’s estimate.Wed, 05 Nov 2025 00:00:00 Z2dd3648c-0651-4949-92df-2234d532f387https://gowlingwlg.com/en-CA/insights-resources/client-work/2025/corporate-energy-transition-team-advises-frontier-powerOur Energy Transition team advised Frontier Power on a £159 million joint venture with Cerberus Capital Management to accelerate UK long-duration energy storage projects under Ofgem’s Cap and Floor regime, securing £44 million initial funding for 16 projects totalling 20GWh capacity.Tue, 04 Nov 2025 00:00:00 Z9770c479-4bde-448b-a80b-e221052c4992https://gowlingwlg.com/en-CA/insights-resources/client-work/2025/corporate-team-acts-for-thg-on-103-million-saleOur Corporate team advised THG on the £103m sale of Claremont Ingredients to Nactarome Group. The transaction supports strategic focus on Myprotein and financial strengthening, with a long-term supply agreement secured. Multiple teams advised across corporate, tax, and real estate.Thu, 04 Sep 2025 00:00:00 Za4332377-15ba-44d7-bb20-7169b2f8e9bchttps://gowlingwlg.com/en-CA/insights-resources/client-work/2025/corporate-energy-transition-sector-team-advises-in-relation-to-the-creation-of-eelpower-energyOur Corporate Energy Transition Sector team has advised long-standing client Eelpower on its participation in a £500 million platform to construct, own, and operate UK BESS assets. The platform is a consortium comprised of Eelpower, Equitix, Aware Super, and the UK's National Wealth Fund.Wed, 27 Aug 2025 00:00:00 Z2541ad6e-0976-4c47-9394-736cca91f558https://gowlingwlg.com/en-ca/insights-resources/articles/2025/canadian-tax-announcements-and-proposed-us-tax-measuresWith major developments in both Canadian and U.S. tax policy—cross-border businesses face new uncertainty and opportunity. In this update, we break down what’s changed, what’s coming, and what it means for your tax planning.Wed, 09 Jul 2025 00:00:00 Zd9bb88e7-5e87-4a69-b6cf-e8ebce2cddc3https://gowlingwlg.com/en-ca/insights-resources/articles/2025/potential-tax-increases-for-canadians-investing-in-the-usProposed U.S. tax changes—including Section 899—could lead to additional U.S. income and withholding taxes, as well as reduced treaty benefits for Canadian businesses and investors. With the proposal moving through Congress, it’s a good time to consider how these measures might affect your U.S. activities and whether any steps should be taken to manage potential tax exposure.Thu, 05 Jun 2025 00:00:00 Zcb85c10f-4277-43eb-bc49-32a4dfe1515fhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2025/corporate-energy-transition-team-advises-the-founders-of-island-green-powerOur Corporate Energy Transition team has advised Island Green Power on an agreement to sell their remaining combined 50% stake in the business to Macquarie Asset Management.Fri, 02 May 2025 00:00:00 Ze5cd7560-6131-4329-8ab7-473a53ba2792https://gowlingwlg.com/en-ca/insights-resources/articles/2025/sr-and-ed-tax-incentiveThe Fall Economic Statement 2024, released on December 16, 2024, provided significant updates to the SR&ED regime.Wed, 26 Feb 2025 00:00:00 Zd8d743a6-22e8-4d4c-a940-ac08ac16ef5dhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2025/corporate-team-advises-on-sale-of-n-able-holdings-ltd-to-rsk-groupOur Corporate team has acted for the shareholders of N-Able Holdings Ltd on the sale of the whole of its issued share capital to RSK Group, a leading integrated environmental, engineering and technical services business, providing end-to-end services.Thu, 20 Feb 2025 00:00:00 Zd91f8113-f2d5-4431-9689-82df5d9a6bc4https://gowlingwlg.com/en-CA/insights-resources/on-demand-webinars/2025/canadian-tax-101-for-us-exporters-common-scenariosJoin our team of tax experts for a webinar designed to guide your business through the complexities of exporting to the Canadian market.Thu, 06 Feb 2025 00:00:00 Zbe8962cf-4574-41b0-aa89-f19b3509cbc2https://gowlingwlg.com/en-ca/insights-resources/articles/2025/listed-quoted-company-transactions-2024-in-reviewIn this article, we've put together some of the highlights from throughout 2024, covering floats, secondary fundraises and mergers and acquisitions across a range of different market sectors and services.Wed, 05 Feb 2025 00:00:00 Z41a96c4a-3065-480a-ba94-0e589262cf50https://gowlingwlg.com/en-ca/insights-resources/client-work/2025/real-estate-team-advises-avison-young-on-the-relocation-of-its-london-headquartersSpecialists from our Real Estate team have advised Avison Young, a global real estate services firm, on the grant of a new lease to move its London headquarters to the recently retrofitted Met Building in Fitzrovia.Mon, 20 Jan 2025 00:00:00 Z446ff0ac-3791-4597-9c38-9b69a425a8f8https://gowlingwlg.com/en-CA/insights-resources/on-demand-webinars/2024/doing-business-in-canadaWelcome to our webinar 'Doing Business with Canada'. In this session, we explore why Canada is an attractive destination for business and investment, focusing on the country's political and economic outlook, key sectors and the stability offered by its legal system.Mon, 23 Dec 2024 00:00:00 Zcb05b2bd-72e3-4d79-bb6a-3af74093be0ahttps://gowlingwlg.com/en-CA/insights-resources/client-work/2024/gladstone-investment-corporation-acquires-pyrotek-special-effectsOn November 21, 2024, Gladstone Investment Corporation (NASDAQ: GAIN), a US-based publicly traded business development company, successfully completed its acquisition of all issued and outstanding shares in the capital of Pyrotek Special Effects Inc.Thu, 21 Nov 2024 00:00:00 Z280e9cbe-b518-422a-b4d0-28be7883c895https://gowlingwlg.com/en-ca/insights-resources/articles/2024/rif-to-be-introduced-by-april-2025This article seeks to draw out the key aspects of the Draft RIF Regs and sets out the key changes that we would like to see in the Updated RIF Regs when released.Wed, 13 Nov 2024 00:00:00 Z00678201-cd57-4470-b187-23049103c75ahttps://gowlingwlg.com/en-ca/insights-resources/articles/2024/ontario-government-announces-changes-to-the-electricity-actOntario's proposed amendments to the Electricity Act aim to encourage local distribution company consolidation by extending tax incentives and attracting private investment.Fri, 08 Nov 2024 00:00:00 Z1075329a-6831-4b7d-8c0f-ba90298434d9https://gowlingwlg.com/en-ca/insights-resources/articles/2024/real-estate-tax-changes-in-the-2024-autumn-budgetThe 2024 Autumn Budget introduced several changes to real estate taxation, reflecting the Government’s focus on raising revenue through targeted tax increases. This article discusses the key property tax changes.Tue, 05 Nov 2024 00:00:00 Zf7a8870c-9048-4aed-92ac-f8af48cb124chttps://gowlingwlg.com/en-ca/insights-resources/articles/2024/autumn-budget-2024---changes-to-carried-interest-taxationAs part of the Autumn Budget 2024, the Government announced that the capital gains tax rate on carried interest will increase from 28% to 32% from April 2025, as well as launching a new consultation on proposed revisions to the taxation of carried interest. This article examines what the impact of this will be.Fri, 01 Nov 2024 00:00:00 Z4565e1e7-3253-4208-a677-d9e5bc739e64https://gowlingwlg.com/en-CA/insights-resources/client-work/2024/kraken-robotics-completes-bought-deal-public-offeringOn October 22, 2024, Kraken Robotics Inc. (TSXV: PNG) (OTCQB: KRKNF) announced that it had closed its previously announced “bought deal” short form prospectus offering of common shares for gross proceeds of $51,750,000 inclusive of the full exercise of the over-allotment option by the underwriters.Tue, 22 Oct 2024 00:00:00 Z0a967e8a-257a-41e1-9cd4-3fc999701699https://gowlingwlg.com/en-ca/insights-resources/articles/2024/flow-through-investing-in-canadaFlow-through shares are an excellent way for many companies spanning multiple industries to raise capital, particularly junior firms in the mining, oil and gas, and renewable energy sectors. As a result of recent changes, flow-through shares could become even more attractive for both issuer corporations and certain investors.Wed, 02 Oct 2024 00:00:00 Zdcb83223-576f-4f70-a42d-f000f99dfa99https://gowlingwlg.com/en-CA/insights-resources/client-work/2024/cross-firm-team-advises-padlock-euro-storageWe have advised Padlock Euro Storage Fund I, Fund II and Fund III on the £102,700,000 loan facility that refinanced the existing debt and provided expansion capital expenditure for existing properties and acquiring new properties.Thu, 19 Sep 2024 00:00:00 Z983c52c0-2e4f-430c-bd47-481859906f77https://gowlingwlg.com/en-ca/insights-resources/articles/2024/is-your-business-ready-for-canadas-digital-services-taxCanada's Digital Services Tax is live as of this summer, and businesses that earn revenue from online platforms should carefully review the legislation in the coming months to avoid any unexpected pitfalls. We cover the ins and outs of the Digital Services Tax Act in our in-depth guide.Thu, 22 Aug 2024 00:00:00 Z49378865-c6c0-4190-a16d-fd4b6988635fhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2023/samuel-son-co-to-sell-service-centersOn August 12, 2024, Samuel, Son & Co., Limited ("Samuel"), a leading metals distributor and industrial products manufacturer, completed the sale of its Western Canada and US carbon plate Service Centre operations to Russel Metals Inc. for approximately $225 million.Mon, 12 Aug 2024 00:00:00 Z5b875842-2e7a-4dd0-8597-cd35b4cf4939https://gowlingwlg.com/en-CA/insights-resources/client-work/2024/firm-capital-mortgage-investment-corporation-completes-22-million-bought-deal-financingOn August 8, 2024, Firm Capital Mortgage Investment Corporation (TSX: FC) announced that it had closed the previously announced bought deal public offering of 1,950,000 common shares at a price of $11.30 per share for gross proceeds of $22,035,000. Following the public offering, the underwriters exercised their over-allotment option in full, resulting in the issue of an additional 292,500 common shares at a price of $11.30 per share. The exercise of the over-allotment option brings the total gross proceeds of the public offering to $25,340,250.Thu, 08 Aug 2024 00:00:00 Z97e96218-7cd1-4858-bbb5-2f317db2b6f5https://gowlingwlg.com/en-ca/insights-resources/articles/2024/tax-considerations-for-gifts-of-art-in-canadaThis article briefly addresses the benefits, requirements and risks of donating art for Canadian taxpayers to consider as part of their estate planning needs.Thu, 18 Jul 2024 00:00:00 Z1b132b24-5d6c-468d-b92f-a8f746b2ffdfhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2024/drillform-acquired-by-roughneck-in-a-cross-border-transactionOn July 17, 2024, Drillform Technical Services Ltd. ("Drillform") was acquired by Roughneck Holding Inc., a subsidiary of HMH, a global drilling equipment product and services group of companies.Wed, 17 Jul 2024 00:00:00 Zc5a22aea-4c55-472d-970c-ece91147dfedhttps://gowlingwlg.com/en-ca/insights-resources/articles/2024/cras-apa-program-revised-guidanceEarlier this year, the Canada Revenue Agency (CRA) published the Revised Circular 94-4R2 on Advanced Pricing Arrangements (APAs). APAs are agreements between the CRA and taxpayers that outline how transfer pricing for specific cross-border transactions with non-resident entities will be handled in advance. This update replaces earlier guidelines and aims to provide Canadian taxpayers with clearer policies and guidelines under the Income Tax Act and Canada's tax treaties, ensuring certainty on transfer pricing.Wed, 10 Jul 2024 00:00:00 Z4585951c-3f14-42b9-a3e5-323e7cb61a0bhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2024/combined-team-advise-on-property-based-dealWed, 26 Jun 2024 00:00:00 Z71e0012a-7f37-4e1a-aabc-2ef1f49cbd06https://gowlingwlg.com/en-CA/insights-resources/client-work/2024/alectra-completes-$200-million-private-placementOn June 13, 2024, Alectra Inc. announced that it had closed its private placement offering of C$200 million aggregate principal amount of 4.627% Series 2024-1 senior unsecured debentures due June 13, 2034.Thu, 13 Jun 2024 00:00:00 Z684aded0-4cf9-4480-a0fb-322a99bbe985https://gowlingwlg.com/en-CA/insights-resources/client-work/2024/alectra-acquires-gagnon-line-constructionOn June 10, 2024, Alectra Energy Services Inc. (a division of Alectra Inc.) announced that it had acquired Gagnon Line Construction (GLC), a storm restoration and electrical services business located in New Brunswick.Mon, 10 Jun 2024 00:00:00 Zc184af54-395b-48be-81ca-053e22de6ca2https://gowlingwlg.com/en-CA/insights-resources/client-work/2024/nexphase-capital-announces-investmentOn June 6, 2024, NexPhase Capital, LP ("NexPhase") announced that it had made an investment in Insurance Systems Inc. ("ISI"), a provider of enterprise software solutions to the property and casualty insurance industry. NexPhase's investment will help enable ISI's continued growth in its existing markets, position the company for expansion into adjacent markets and facilitate continued product improvements designed to allow for more integrations, faster implementation and enhanced analytics for new and existing customers.Thu, 06 Jun 2024 00:00:00 Z9c33f051-fc43-4107-b469-407bc526df83https://gowlingwlg.com/en-CA/insights-resources/client-work/2024/groupe-touchette-acquisitionOn June 4, 2024, Touchette Retail & Commercial, a business unit of Groupe Touchette, the largest Canadian-owned tire distributor, announced a strategic partnership with Pneus Bélisle, a leader in passenger, commercial, civil engineering, industrial, and agricultural tires in Quebec.Tue, 04 Jun 2024 00:00:00 Za2951cc6-d36b-4da0-9a27-429465783c63https://gowlingwlg.com/en-ca/insights-resources/articles/2024/new-rules-for-deducting-patent-costsBudget 2024 introduced new rules for the immediate 100 per cent deduction of capital acquisition costs of certain capital assets, including patents.Wed, 29 May 2024 00:00:00 Zaa4c27d8-a150-444d-a759-6b8c67cce2c5https://gowlingwlg.com/en-ca/insights-resources/articles/2024/canada-proposed-patent-box-regimeIn January 2024, the Department of Finance released a consultation paper on a proposed patent box regime, aiming to tax income from certain intellectual properties (IP) at preferential rates lower than the current federal rate.Tue, 28 May 2024 00:00:00 Z1b0bf656-a42a-4446-ab0c-4e9a68e93653https://gowlingwlg.com/en-CA/insights-resources/client-work/2024/novatech-group-acquired-by-garagaOn May 22, 2024, the Gendreau family, Canadian owners of Garaga Inc., a North American pioneer in the manufacture of garage doors, announced the acquisition of Novatech Group Inc. ("Novatech"), a cutting-edge Canadian company specializing in the manufacture of entry doors, doorglass, patio doors and tailor-made insulated glass. The companies have a combined annual turnover exceeding $1 billion and more than 3,000 employees.Wed, 22 May 2024 00:00:00 Z052c00a7-49b7-4b8f-a785-f4cd264b8851https://gowlingwlg.com/en-CA/insights-resources/client-work/2024/sandstorm-gold-royalties-announces-saleOn May 2, 2024, Sandstorm Gold Ltd. ("Sandstorm") announced that it had signed a definitive asset purchase agreement with Evolve Strategic Element Royalties Ltd. ("Evolve") to sell eight non-core, non-precious metals royalties to Evolve for cash proceeds of US$21 million plus the retention of the next US$10 million in proceeds from a 2.5–5.0% net smelter returns royalty on the North Pit at the Copper Mountain mine in British Columbia.Thu, 02 May 2024 00:00:00 Z0bdfb070-0196-4206-80bd-e7f29e247ad1https://gowlingwlg.com/en-CA/insights-resources/client-work/2024/zijin-to-purchase-la-arena-in-peruOn May 1, 2024, Pan American Silver Corp. (NYSE: PAAS) (TSX: PAAS) ("Pan American") announced that it had agreed to sell its 100% interest in La Arena S.A. ("La Arena"), which owns the La Arena gold mine as well as the La Arena II project in Peru, to Jinteng (Singapore) Mining Pte. Ltd., a subsidiary of Zijin Mining Group Co., Ltd. (collectively, "Zijin") for US$245 million cash upfront and a US$50 million contingent payment.Wed, 01 May 2024 00:00:00 Zd2c1025f-6a77-4355-83fe-a757e3a2c13fhttps://gowlingwlg.com/en-ca/insights-resources/articles/2024/budget-2024-fairness-for-every-generationThe Liberal government's budget allocates $52.9 billion over five years, prioritizing housing, affordability, fairness for every generation, and driving economic growth in a way that’s shared by all. Our summary of Budget 2024 provides key insights into its implications for Canadians.Wed, 17 Apr 2024 00:00:00 Z99abe71e-f121-433f-809d-0b897f02731chttps://gowlingwlg.com/en-CA/insights-resources/articles/2024/federal-budget-2024-tax-measures-changing-voterOn April 16, 2024, Deputy Prime Minister and Finance Minister Chrystia Freeland delivered the 2024 federal budget (Budget 2024), with spending measures aimed largely at this demographic, using promises of affordable rental housing and first-time home buyer incentives. The corollary, Budget 2024 also introduces measures to fund this new spending, principally via an increase in capital gains taxes that the Department of Finance expects to affect 0.13 per cent of the wealthiest Canadians.Wed, 17 Apr 2024 00:00:00 Z369a5059-7b45-4f62-9e5d-56e953cec392https://gowlingwlg.com/en-CA/insights-resources/client-work/2024/cross-firm-team-advises-h-t-groupWe have advised the UK's largest pawnbroker and a leading retailer of high quality new and pre-owned jewellery and watches, H&T Group, on its acquisition of certain assets of Maxcroft Securities Ltd, for a cash consideration of £11.3 million.Tue, 05 Mar 2024 09:24:00 Z7051e04a-b1bb-48a1-bfd8-8d3afb21ed29https://gowlingwlg.com/en-CA/insights-resources/client-work/2024/aga-benefit-solutions-welcomes-investment-from-taOn March 5, 2024, AGA Benefit Solutions ("AGA") announced that it had received a significant growth investment from leading global private equity firm TA Associates ("TA"). As part of the transaction, Novacap, a leading North American private equity firm which invested in the business in 2020 out of its inaugural financial services fund, will transition its ownership position. AGA's management team will remain in place and continue to be major shareholders of AGA.Tue, 05 Mar 2024 00:00:00 Z1106a5f3-3cf2-431d-bb5a-85dc38aed0bahttps://gowlingwlg.com/en-CA/insights-resources/client-work/2024/acrobatic-arts-sells-business-to-ensemble-performing-artsOn February 28, 2024, Acrobatic Arts Inc. sold substantially all of its assets to Acrobatic Arts LLC and Ensemble Performing Arts Canada ULC.Wed, 28 Feb 2024 00:00:00 Zcf5c8560-bdbb-473c-8c7e-4381c6e0f2ebhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2024/exro-technologies-closes-bought-deal-financingOn February 16, 2024, Exro Technologies Inc. (TSX: EXRO) (OTCQB: EXROF) ("Exro") announced the closing of its previously announced bought deal private placement offering of subscription receipts for total gross proceeds of approximately $30 million. The offering was made through a syndicate of underwriters co-led by Canaccord Genuity Corp. and Eight Capital.Fri, 16 Feb 2024 00:00:00 Ze9eac105-ffb0-4d7e-b8aa-98c46a3a59d8https://gowlingwlg.com/en-CA/insights-resources/client-work/2024/ovivo-completes-acquisition-of-e2metrixOn February 15, 2024, Ovivo Inc. ("Ovivo"), a global provider of water and wastewater treatment equipment, technologies and systems, announced its acquisition of E2metrix Inc. ("E2metrix").Thu, 15 Feb 2024 00:00:00 Zeafcc9d1-e50f-4c26-9663-22576781ab83https://gowlingwlg.com/en-CA/insights-resources/client-work/2024/geologicai-acquires-resource-modeling-solutionsOn February 13, 2024, Enersoft Inc. (dba GeologicAI), a leading innovator in mining technology, announced its strategic acquisition of Resource Modeling Solutions (RMS).Tue, 13 Feb 2024 00:00:00 Z890564b0-73f6-4661-9ac0-788a87f3a6e7https://gowlingwlg.com/en-CA/insights-resources/client-work/2024/apogee-interactive-acquires-energyx-solutionsOn February 7, 2024, Apogee Interactive, Inc. ("Apogee") announced the acquisition of EnergyX Solutions, Inc., an Ontario-based creator of artificial-intelligence-powered software for utilities. Operating in the US and Canada, EnergyX leverages data science to increase customer participation in energy efficiency programs.Wed, 07 Feb 2024 00:00:00 Z5cf55f8a-c5ea-4e3f-b8f2-b39dd41747fbhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2024/egb-capital-acquires-central-valley-glassEffective February 1, 2024, EGB Capital Inc. acquired Bartz Enterprises (Central Valley Glass), the first acquisition in its portfolio.Thu, 01 Feb 2024 00:00:00 Ze0564c17-4538-45eb-9794-a61878214afchttps://gowlingwlg.com/en-CA/insights-resources/client-work/2024/real-tech-target-of-cross-border-acquisitionOn February 1, 2024, ABB Inc., a technology leader in electrification and automation headquartered in Zurich, Switzerland, completed its previously announced acquisition of Real Tech Inc., a leading supplier of innovative optical sensor technology that enables real-time water monitoring and testing, based in Whitby, Ontario.Thu, 01 Feb 2024 00:00:00 Z47b90ac9-0922-47b7-979f-eb1a34b671d1https://gowlingwlg.com/en-CA/insights-resources/client-work/2024/cree-first-nation-of-waswanipi-completes-projectOn January 18, 2024, Osisko Mining Inc. announced that the 85 km long 69 kV hydro-electric power line built, owned and operated by the Waswanipi Cree First Nation and its related business entities had been completed on schedule, and grid power had successfully been connected to the Windfall Project.Thu, 18 Jan 2024 00:00:00 Z6d16fa9f-732d-418e-b793-145794f85ddahttps://gowlingwlg.com/en-CA/insights-resources/client-work/2024/red-white-bloom-closes-aleafia-transactionOn January 15, 2024, Red White & Bloom Brands Inc. (CSE: RWB) (OTC: RWBYF) ("RWB") announced that, in connection with the proceedings of Aleafia Health Inc. and certain of its subsidiaries under the Companies' Creditors Arrangement Act, the parties have successfully closed the previously announced sale transaction. Total consideration for the transaction was $31,667,700.Mon, 15 Jan 2024 00:00:00 Z42fe3bfe-ba4d-4d5f-b3a7-3bd7b373d4dfhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2024/senske-acquisition-of-nutri-lawn-and-mosquito-buzzOn January 12, 2024, Senske Services, a US leader in recurring residential lawn care, pest control, and home services, announced its strategic acquisition of Nutri-Lawn and Mosquito.buzz in Canada.Fri, 12 Jan 2024 00:00:00 Z8bbceb7d-c012-4914-b764-2d0ece598101https://gowlingwlg.com/en-CA/insights-resources/client-work/2023/horizon-aircraft-goes-public-via-spac-transactionOn January 12, 2024, Robinson Aircraft Ltd., a Lindsay, Ontario-based company doing business as Horizon Aircraft ("Horizon Aircraft") and Pono Capital Three, Inc., a special purpose acquisition company, announced the completion of their previously announced business combination.Fri, 12 Jan 2024 00:00:00 Z8523c254-6cd4-46c0-aa98-dab507b8a657https://gowlingwlg.com/en-CA/insights-resources/client-work/2024/canadian-dental-acquires-davis-orthodonticsOn January 8, 2024, Canadian Dental Services Corporation ("CDS"), a leading participant in multi-dental office management across Canada, announced the acquisition of Davis Orthodontics, the premier orthodontic services network in Canada, with 13 branded clinics around the Greater Toronto Area.Mon, 08 Jan 2024 00:00:00 Z34eecff2-441e-4790-8779-7b2e77782413https://gowlingwlg.com/en-CA/insights-resources/client-work/2023/neoterrex-closes-qualifying-transactionOn December 22, 2023, NeoTerrex Minerals Inc. (formerly, Spitfyre Capital Inc.) ("NeoTerrex") (TSXV: FYRE.P) announced the closing of its previously announced Qualifying Transaction, pursuant to the terms of a business combination agreement dated October 4, 2023.Fri, 22 Dec 2023 00:00:00 Z38105b54-d4f4-4447-9fb2-f653a3242c5ahttps://gowlingwlg.com/en-CA/insights-resources/videos/2023/single-family-rental/single-family-rental-taxOur Market Masterclass video series aims to help you navigate the promising landscape of single family rental. In our latest video in the series, partner Matthew Poole explains the complex taxation landscape in this emerging market and any future changes to be aware of.Mon, 18 Dec 2023 00:00:00 Z070c7f98-0388-49d9-b72c-3114093135d1https://gowlingwlg.com/en-ca/insights-resources/articles/2023/financial-services-sector-announcements-in-2023On Nov. 21, 2023, the Government of Canada released its 2023 Fall Economic Statement (FES 2023). Although FES 2023 contained no new draft legislation relevant to the government’s oversight of the financial services sector, FES 2023 contained a number of important announcements for the sector described in greater detail below.Mon, 27 Nov 2023 14:18:00 Zcbc346d3-1156-4f07-8c6e-88379674379dhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2023/novacap-portfolio-company-gti-group-acquiredOn November 27, 2023, Canada Cartage Corporation, one of Canada's largest transportation and logistics providers, announced it had entered into a definitive agreement to acquire The GTI Group ("GTI"), a portfolio company of private equity firm Novacap.Mon, 27 Nov 2023 00:00:00 Z1ba3c5d4-b556-4caa-879d-7ed8b9072b8ehttps://gowlingwlg.com/en-ca/insights-resources/articles/2023/tax-measures-2023-fall-economic-statementIn a time of high interest rates, increasing debt servicing costs and lower than expected growth, Deputy Prime Minister and Minister of Finance Chrystia Freeland delivered the Government'’s Fall Economic Statement (FES 2023) in the House of Commons on November 21, 2023.Wed, 22 Nov 2023 00:00:00 Zb104268d-7795-458b-9d74-33955aca7cdfhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2023/fgs-global-acquires-longviewOn November 21, 2023, FGS Global announced that it had acquired Longview Communications and Public Affairs.Tue, 21 Nov 2023 00:00:00 Z725f7899-b721-4fd7-ab15-0009243dccdchttps://gowlingwlg.com/en-CA/insights-resources/client-work/2023/coelacanth-energy-closes-bought-deal-financingOn November 15, 2023, Coelacanth Energy Inc. (TSXV: CEI) announced that it had closed its previously announced bought-deal financing of 100 million units of the company for gross proceeds of $80 million.Wed, 15 Nov 2023 00:00:00 Z650057ca-1462-4ae7-9f18-8104b35a7c9chttps://gowlingwlg.com/en-CA/insights-resources/client-work/2023/gestalt-capital-inc-completes-investmentOn November 14, 2023, North American private equity firm Gestalt Capital Inc. completed its acquisition of all of the issued and outstanding shares of 1772486 Ontario Inc. ("177 ON").Tue, 14 Nov 2023 00:00:00 Z20523b9b-ada7-4630-9f91-31ea9f9612c9https://gowlingwlg.com/en-CA/insights-resources/client-work/2023/imech-acquired-by-timkenOn November 1, 2023, The Timken Company (NYSE: TKR) completed its previously announced acquisition of Engineered Solutions Group (a.k.a. Innovative Mechanical Solutions or iMECH).Wed, 01 Nov 2023 00:00:00 Z64f183a2-7d4b-4dd6-aef2-06ef0c212dcbhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2023/sandbox-royalties-closes-gold-purchase-agreementOn October 31, 2023 Sandbox Royalties Corp. ("Sandbox") together with Regal Resources Royalty Fund ("Regal") closed a US$75 million amended and restated Gold Purchase Agreement ("GPA") with Equinox Gold Corp. ("Equinox Gold").Tue, 31 Oct 2023 00:00:00 Z6cb4a632-2989-4344-ae22-99216879921dhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2023/perwyn-private-equity-partnership-with-iampropertyA cross firm team has advised Perwyn on its new private equity partnership with property technology provider, iamproperty.Fri, 27 Oct 2023 00:00:00 Z5b2e7839-0170-4277-9bf8-0bed4db71a99https://gowlingwlg.com/en-ca/insights-resources/client-work/2023/cybin-completes-acquisition-of-small-pharmaOn October 23, 2023, Cybin Inc. (NYSE American:CYBN) (NEO:CYBN) ("Cybin") acquired Small Pharma Inc. (TSXV:DMT) (OTCQB:DMTTF) ("Small Pharma") by way of a plan of arrangement under the Business Corporations Act (British Columbia).Mon, 23 Oct 2023 00:00:00 Zf0c7d213-f0c1-4865-91b4-5bdd0af8fd32https://gowlingwlg.com/en-ca/insights-resources/client-work/2023/damon-motors-announces-proposed-mergerOn October 23, 2023, Damon Motors Inc. ("Damon") announced that it had signed a definitive agreement with Inpixon to complete a cross-border reverse merger (the "Business Combination") with Grafiti Holding Inc. ("Grafiti"), a proposed spin-off entity of Inpixon, a Nasdaq-listed issuer.Mon, 23 Oct 2023 00:00:00 Z1b7044a8-161c-4f25-9899-38d4526283a8https://gowlingwlg.com/en-ca/insights-resources/client-work/2023/itm-and-cnl-announce-launch-of-joint-ventureOn October 18, 2023, ITM Isotope Technologies Munich SE ("ITM"), a leading radiopharmaceutical biotech company, and Canadian Nuclear Laboratories ("CNL"), which manages and operates the national laboratory at Chalk River, Ontario on behalf of Atomic Energy of Canada Limited ("AECL"), announced the launch of Actineer™ Inc., a new joint venture company between CNL and ITM for the industrial scale production of Actinium-225 (225Ac).Wed, 18 Oct 2023 00:00:00 Z807e6606-10c3-4d87-99df-b438137268cdhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2023/key-advice-provided-to-ahk-designs-on-acquisitionOur corporate restructuring and insolvency practice has led a multidisciplinary team advising e-commerce retailer AHK Designs Ltd (an affiliate of our client Giomani Designs) on its acquisition of the business and assets of Victoria Plum, the UK's largest online bathroom retailer.Thu, 05 Oct 2023 00:00:00 Zb03739f2-c896-4581-a42e-938ad8c089f4https://gowlingwlg.com/en-ca/insights-resources/client-work/2023/skift-acquires-tourism-consulting-firm-twenty31On September 27, 2023, New York City-based Skift, Inc. announced that it had acquired Vancouver-based tourism and destination management consulting firm, Twenty31.Wed, 27 Sep 2023 00:00:00 Z15dbae0a-6941-4e9a-8f14-b22a20197622https://gowlingwlg.com/en-CA/insights-resources/client-work/2023/metsa-tissue-supported-on-multi-million-poundOur Real Estate, Tax and Planning teams have advised Metsä Tissue, part of Metsä Group in its choice to develop a new, modern tissue factory in Goole, Yorkshire.Fri, 22 Sep 2023 10:51:00 Zee75812c-2733-4d64-a3f3-7329aff7bac6https://gowlingwlg.com/en-CA/insights-resources/client-work/2023/brimich-logistics-target-of-strategic-investmentOn September 6, 2023, TorQuest Partners, one of Canada's leading private equity firms, announced that it had completed an investment in Brimich Logistics, a full-service, family owned and operated supply chain management and third-party logistics (3PL) business.Wed, 06 Sep 2023 00:00:00 Zb695a8ed-8a65-498c-9d1d-b3ed2270608chttps://gowlingwlg.com/en-CA/insights-resources/client-work/2023/mather-economics-acquires-sophiOn August 22, 2023, Mather Economics LLC ("Mather") announced that it had acquired Sophi, Inc. ("Sophi"), an AI-powered solution for the modern newsroom. Mather is a subsidiary of Mediahuis. Sophi was a subsidiary of The Globe and Mail.Tue, 22 Aug 2023 00:00:00 Z58c54cff-90db-4a44-bff1-e579b08f286ehttps://gowlingwlg.com/en-CA/insights-resources/client-work/2023/horizon-aircraft-to-go-public-via-spac-transactionOn August 15, 2023, special purpose acquisition company Pono Capital Three, Inc. (NASDAQ: PTHR) ("Pono") announced the execution of a definitive Business Combination Agreement with Robinson Aircraft Ltd., a Lindsay, Ontario-based company doing business as Horizon Aircraft ("Horizon Aircraft").Tue, 15 Aug 2023 00:00:00 Zcb5d254f-27de-4f07-aab3-13e431fd1600https://gowlingwlg.com/en-ca/insights-resources/client-work/2023/tevva-and-electrameccanica-cross-border-mergerOn August 15, 2023, Tevva, a UK-based pioneer in electric medium- and heavy-duty commercial vehicles, and ElectraMeccanica (NASDAQ: SOLO), a US-based designer and assembler of electric vehicles, announced that they had entered into a definitive arrangement agreement to merge the companies and list the Delaware-domiciled resulting issuer on the Nasdaq exchange.Tue, 15 Aug 2023 00:00:00 Z8c3e2a0f-135a-4309-bab3-9d8fc444eac7https://gowlingwlg.com/en-ca/insights-resources/client-work/2023/blue-ant-media-and-marblemedia-merge-productionEffective August 10, 2023, Blue Ant Media and marblemedia merged their production and distribution operations into one unified studio and rights business.Thu, 10 Aug 2023 00:00:00 Zb7f82ddc-c444-4fb4-8002-cf24d19802adhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2023/tripleseat-announces-strategic-acquisitionOn August 8, 2023, Tripleseat, the leading innovator in cloud-based event management software for the hospitality industry, announced its strategic acquisition of Vancouver-based Attendease, a world-class meeting and event software for enterprise and corporate event planners.Tue, 08 Aug 2023 00:00:00 Ze3d30153-2a0f-4fc6-a558-589c3f002f9chttps://gowlingwlg.com/en-CA/insights-resources/client-work/2023/timeframe-shareholders-advised-on-stock-saleOur team in Frankfurt has advised shareholders of timeframe on the company's sale to Transcom, a global leader in digital customer experience solutions.Fri, 21 Jul 2023 00:00:00 Z7fe48acb-f7ac-49b4-9549-4491e927bdf9https://gowlingwlg.com/en-CA/insights-resources/client-work/2023/roxborough-acquired-by-switzer-cartyEffective June 30, 2023, Roxborough Bus Lines and its wholly-owned subsidiary 417 Bus Line were acquired by Switzer-CARTY Transportation.Fri, 30 Jun 2023 00:00:00 Ze3691d4f-07a9-43aa-b7da-2f773980f29ahttps://gowlingwlg.com/en-ca/insights-resources/client-work/2023/corporate-team-advises-volex-on-major-acquisitionOur Corporate team has advised integrated manufacturing specialist Volex on its proposed acquisition of Murat Ticaret Kablo Sanayi A.Ş. - a leading manufacturer of complex wire harnesses, for approximately €178.1 million.Thu, 29 Jun 2023 08:40:00 Z1e5358d9-3270-474b-ba30-e22caa0e49cbhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2023/ironwood-and-vectivbio-announce-completionOn June 29, 2023, Ironwood Pharmaceuticals, Inc. ("Ironwood") (Nasdaq: IRWD) and VectivBio Holding AG ("VectivBio") (Nasdaq: VECT) announced the successful completion of Ironwood's tender offer to purchase the outstanding ordinary shares of VectivBio for $17.00 per share in cash.Thu, 29 Jun 2023 00:00:00 Z6c443d76-d7d9-45ff-a3ad-3306aa6a7af7https://gowlingwlg.com/en-CA/insights-resources/client-work/2023/persist-oil-and-gas-acquires-dienerian-resourcesOn June 27, 2023, Persist Oil and Gas Inc. ("Persist") acquired Dienerian Resources Inc. ("Dienerian").Tue, 27 Jun 2023 00:00:00 Zf05646b6-d12a-4fe2-a1ab-0d843e0da21fhttps://gowlingwlg.com/en-ca/insights-resources/articles/2023/finance-canada-overhaul-transfer-pricing-frameworkThis article discusses the Department of Finance Canada's ("Finance Canada") proposed legislative changes to section 247 of the Income Tax Act (Canada) ("Act"), introduced to eliminate certain perceived issues with the current legislation and align Canada's transfer pricing rules with the current international consensus.Mon, 26 Jun 2023 19:55:00 Z2abe3e59-6775-4538-b363-ef3178ec5ae1https://gowlingwlg.com/en-ca/insights-resources/articles/2023/budget-2023-gaar-amendments-rewriting-rulesTaxpayers are free to arrange their affairs to reduce their tax liability. That said, tax planning subsists within a web of charging and relieving provisions, judicial anti-avoidance doctrines, and specific anti-avoidance rules ("SAARs") that foreclose certain strategies. However, SAARs do not completely delineate the boundaries of legitimate planning and abusive avoidance.Mon, 26 Jun 2023 19:54:00 Z06202b59-adc6-4c8c-b5a3-c798d34dc0d4https://gowlingwlg.com/en-ca/insights-resources/articles/2023/oecd-solution-reshaping-international-taxationThe OECD's comprehensive two-pillar solution is designed to reform international tax rules and address the tax challenges arising from globalization and digitalization.Mon, 26 Jun 2023 19:54:00 Z57bfe15e-70bc-4efc-aa8b-eda7bac739cchttps://gowlingwlg.com/en-CA/insights-resources/client-work/2023/1663439-alberta-ltd-sells-50-ownership-stakeOn June 23, 2023, 1663439 Alberta Ltd. sold its 50% ownership stake in Cougar Contractors Ltd. and 2126178 Alberta Ltd. to Almeida Investment Management Inc. of Calgary, Alberta.Fri, 23 Jun 2023 00:00:00 Z1b452a85-04ec-4c4d-af32-71751f4e7d86https://gowlingwlg.com/en-CA/insights-resources/client-work/2023/structurlam-mass-timber-acquired-by-mercerOn June 15, 2023, global forest products company Mercer International Inc. ("Mercer") (Nasdaq: MERC) completed the previously-announced acquisition of substantially all of the assets of Structurlam Mass Timber Corporation and its US and Canadian affiliates (collectively, "Structurlam"), a leading North American provider of mass timber solutions for construction and industrial markets in Canada and the US.Thu, 15 Jun 2023 00:00:00 Z7e2b17c4-d76c-4b10-90f8-e09a09b6fbb3https://gowlingwlg.com/en-CA/insights-resources/client-work/2023/pandell-technologies-acquired-by-esgOn June 1, 2023, Pandell Technologies Inc. ("Pandell") completed the sale of all of its issued and outstanding shares to ESG, a global leader in energy SaaS solutions. In connection with the transaction, Pandell also completed a pre-closing reorganization that included the conversion from a corporation to an unlimited liability company.Thu, 01 Jun 2023 00:00:00 Zdc9c273a-7f38-42ff-af47-1b104f12af44https://gowlingwlg.com/en-ca/insights-resources/client-work/2023/strong-global-entertainment-inc-closes-ipoOn May 18, 2023, Strong Global Entertainment, Inc. ("Strong") (NYSE American: SGE), announced the closing of its initial public offering ("IPO") of Class A Common Voting Shares.Thu, 18 May 2023 00:00:00 Z493905ca-697f-4718-96dc-372e9922a53ehttps://gowlingwlg.com/en-CA/insights-resources/client-work/2023/partnerhero-acquires-summattiOn May 4, 2023, leading customer operations outsourcing innovator PartnerHero acquired Summatti.Thu, 04 May 2023 00:00:00 Z7336a811-15be-400f-9161-5b43cf315c9bhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2023/above-food-corp-to-list-on-nyse-through-de-spacOn May 1, 2023, Above Food Corp. ("Above Food") and Bite Acquisition Corp. (NYSE AMERICAN: BITE) ("Bite"), a US special purpose acquisition company "SPAC"), announced that they have entered into a definitive business combination agreement, which values Above Food at a pro forma enterprise value of approximately US$319 million (approximately Cdn$430 million).Mon, 01 May 2023 00:00:00 Zf71d3682-d226-4844-875a-5051c881d55fhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2023/gresham-house-renewable-energy-vcts-saleA cross firm team has advised venture capital trusts Gresham House Renewable Energy VCT 1 and VCT 2 plc, which invest in a portfolio of renewable energy projects in the UK, on their sale of UK Solar Assets to Downing Renewables & Infrastructure Trust plc.Thu, 27 Apr 2023 00:00:00 Z1ecf40c0-536f-414c-a0e4-ab619b8f9f4chttps://gowlingwlg.com/en-CA/insights-resources/client-work/2023/genai-target-of-reverse-takeover-by-ultron-capitalOn April 17, 2023, Generative AI Solutions Corp. ("GenAI" or the "Company") (CSE: AICO) (‎FSE: 99L.F) (OTC: IDLSF), Ultron Capital Corp. ("Ultron") and a wholly owned subsidiary of the Company completed a business combination under which GenAI acquired all of the issued and outstanding securities of Ultron in exchange for 51,176,001 common shares of the Company.Mon, 17 Apr 2023 00:00:00 Z96d2b4f9-fa09-4e06-94e9-f892c7fe54e7https://gowlingwlg.com/en-CA/insights-resources/client-work/2023/quebec-government-awards-contractOn April 17, 2023, the Québec government announced that it had concluded a comprehensive Design Build Finance contract providing for the replacement of the existing Île-aux-Tourtes Bridge and the deconstruction of the existing bridge. Work on the approximately $2.0 billion project has already begun.Mon, 17 Apr 2023 00:00:00 Zc49ca072-7f1a-4f5a-81ed-054d967345e0https://gowlingwlg.com/en-CA/insights-resources/client-work/2023/aquateck-west-acquired-by-delta-irrigationOn April 3, 2023, Delta Irrigation Products Ltd., an irrigation equipment supplier headquartered in Kamloops, British Columbia, completed its acquisition of Aquateck West Ltd., a wholesale distributor and consultant for pumps and water systems, headquartered in Edmonton, Alberta.Mon, 03 Apr 2023 00:00:00 Z3dae3bc8-6930-4379-ad0e-b3a58ec9b535https://gowlingwlg.com/en-CA/insights-resources/client-work/2023/nfu-mutual-on-its-sixth-build-to-rent-investmentWe have advised NFU Mutual on its investment into a series of large, premium build-to-rent developments across the UK. The investment joint venture now includes six assets, representing a total of 3,050 homes.Mon, 03 Apr 2023 00:00:00 Z0b764a59-50cb-4a2b-8160-a48fd65545f4https://gowlingwlg.com/en-ca/insights-resources/client-work/2023/interra-and-alto-verde-business-combinationOn March 31, 2023, Interra Copper Corp. (CSE: IMCX) (OTCQB: IMIMF) (FRA: 3MX) ("Interra") announced that it had completed its previously announced business combination with Alto Verde Copper Inc. ("Alto Verde") pursuant to a business combination agreement dated March 8, 2023 between Interra, Alto Verde and 1000465623 Ontario Inc., a wholly-owned subsidiary of Interra, pursuant to which Interra acquired all of the issued and outstanding shares in the capital of Alto Verde.Fri, 31 Mar 2023 00:00:00 Zcaea780b-c797-4973-8a69-c4c697afb29dhttps://gowlingwlg.com/en-ca/insights-resources/articles/2023/federal-budget-2023Federal Budget 2023 (Budget 2023) assumes a moderately positive fiscal outlook, expecting that the "looming" recession will be "shallow."Wed, 29 Mar 2023 00:00:00 Z41ca1e9e-4856-4751-9d23-6dedd227e787https://gowlingwlg.com/en-CA/insights-resources/client-work/2023/corporate-team-advises-scc-on-vohkus-acquisitionOur Corporate team has advised IT solutions provider Specialist Computer Centres plc on its acquisition of Vohkus (a £100 million turnover IT reseller).Thu, 23 Mar 2023 00:00:00 Z28fd45b4-f4b1-4f12-b4a5-02ad9ffded95https://gowlingwlg.com/en-ca/insights-resources/articles/2023/indigenous-self-government-taxationChange opens the door to withdrawal from the Indian Act in favour of a negotiated nation-to-nation self-government agreement.Wed, 22 Mar 2023 00:00:00 Ze92d8018-4478-4613-b3af-be7fdf201133https://gowlingwlg.com/en-CA/insights-resources/client-work/2023/perkinelmer-completes-us2-45-billion-saleOn March 13, 2023, PerkinElmer Inc. (NYSE: PKI) announced that it had successfully completed the previously announced divestiture of its Applied, Food and Enterprise Services businesses to New Mountain Capital, a growth-oriented investment firm.Mon, 13 Mar 2023 00:00:00 Z0de61f74-4087-4888-938f-6fe6a1781b72https://gowlingwlg.com/en-ca/insights-resources/articles/2023/five-considerations-settling-tax-litigationSettlements are an integral part of a tax litigation practice. Thousands of tax appeals are filed every year with the Tax Court of Canada, the majority of which never make it to trial. This is because most tax appeals are settled.Tue, 28 Feb 2023 00:00:00 Z2b6b1b50-986f-43cd-a802-d7bec912ea7bhttps://gowlingwlg.com/en-ca/insights-resources/articles/2023/taxpayer-relief-at-objection-stage-asare-v-rSubsection 220(3.1) of the Income Tax Act (Canada) grants the Canada Revenue Agency ("CRA") the discretion to waive or cancel penalties and interest. While this provision is the legislative authority for the CRA's taxpayer relief and voluntary disclosures programs, its scope and operation are broader than the relief those programs grant pursuant to the CRA's administrative guidelines.Tue, 28 Feb 2023 00:00:00 Z476f1715-171e-4f32-b8b1-93604ee95cd3https://gowlingwlg.com/en-ca/insights-resources/articles/2023/interlocutory-injunction-not-grantedIn a recent case, the Ontario Superior Court of Justicedismissed a motion seeking an interlocutory injunction prohibiting the Canada Revenue Agency from rendering its final audit decision.Tue, 28 Feb 2023 00:00:00 Zc8a478b5-37f5-4372-a2d7-1284bba6b4d2https://gowlingwlg.com/en-ca/insights-resources/articles/2023/ten-keys-to-resolving-sr-and-ed-claimsScientific research and experimental development ("SR&ED") claims can present some of the most complex and challenging tax disputes, requiring a practical and pragmatic approach. Here are ten keys to successfully resolve SR&ED disputes.Tue, 28 Feb 2023 00:00:00 Ze9fe694c-933b-4f8a-98cd-fda661aa1043https://gowlingwlg.com/en-ca/insights-resources/client-work/2023/q2-metals-completes-private-placement-financingOn February 23, 2023, Q2 Metals Corp. (TSXV: QTWO) (OTCQB: QUEXF) (FSE: 458) announced that it had completed its previously announced private placement financing for aggregate proceeds to the company of $10.25 million, consisting of 12,908,333 units.Thu, 23 Feb 2023 00:00:00 Ze99e3ef7-0805-4794-9740-3bfa9e1e2324https://gowlingwlg.com/en-CA/insights-resources/client-work/2023/elemental-altus-acquires-royalty-portfolioOn February 21, 2023, Elemental Altus Royalties Corp. ("Elemental Altus") (TSXV: ELE) (OTCQX: ELEMF) announced that it had completed its previously announced acquisition of 19 mining royalties in Canada, the US, Mexico and Burkina Faso, from a wholly owned subsidiary of First Mining Gold Corp. (TSX: FF) (OTCQX: FFMGF).Tue, 21 Feb 2023 00:00:00 Z53a790e0-9a28-4f59-bdc2-8aa48345e494https://gowlingwlg.com/en-CA/insights-resources/client-work/2023/purely-crm-merges-with-endeavour-solutionsOn February 13, 2023, Purely CRM Consulting Inc. and Endeavour Solutions Inc. completed a merger between their two organizations.Mon, 13 Feb 2023 00:00:00 Zc8460c03-3ae6-4131-aac8-820fe1937c1bhttps://gowlingwlg.com/en-CA/insights-resources/videos/2022/influencers-in-torontoIn this series, you will meet a number of practitioners in our Toronto office who have helped their clients overcome a variety of complex legal obstacles.Thu, 09 Feb 2023 18:59:00 Z92b97cc3-0974-4df1-956b-ad7bfe02bf27https://gowlingwlg.com/en-CA/insights-resources/client-work/2023/cooper-equipment-rentals-acquires-hub-equipmentOn February 7, 2023, Cooper Equipment Rentals Limited ("Cooper"), the leading Canadian-owned and operated construction equipment rental company, announced that it had purchased 100% of the shares of Toronto-based Hub Equipment ("Hub"). Hub will operate as a Specialty Division of Cooper.Tue, 07 Feb 2023 00:00:00 Z1e5ba26f-9d9b-43b1-a1b4-cf7b11bb4960https://gowlingwlg.com/en-ca/insights-resources/client-work/2023/cairngorm-capital-partners-major-m-a-dealA health-sector focused team from Gowling WLG has assisted Cairngorm Capital Partners LLP (Cairngorm Capital) on the merging of its portfolio company, E-zec Medical Transport Services (E-zec) with ERS Transition Limited (trading as ERS Medical).Fri, 03 Feb 2023 00:00:00 Za792a7df-6b3a-4542-b765-713d516906e3https://gowlingwlg.com/en-CA/insights-resources/client-work/2023/xillio-makes-strategic-investment-in-colligoOn January 26, 2023, Xillio made a strategic investment in Colligo, as part of a strategic partnership between the companies to deliver end-to-end, Microsoft 365 enterprise migration capabilities to organizations across the globe.Thu, 26 Jan 2023 00:00:00 Z3529c816-c75c-4540-b985-6b53f85480c9https://gowlingwlg.com/en-ca/insights-resources/client-work/2023/capital-paper-recycling-acquiredOn January 17, 2023, Environmental 360 Solutions Ltd. ("E360S") announced that it had acquired Capital Paper Recycling Ltd. ("Capital Paper").Tue, 17 Jan 2023 00:00:00 Z02171300-c725-47af-82c4-d73a524d830bhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2023/skybox-labs-target-of-cross-border-acquisitionOn January 6, 2023, China-based NetEase, Inc. (NASDAQ: NTES) (HKEX: 9999), a leading internet and game services provider, announced that its game division, NetEase Games, had acquired SkyBox Labs Inc., a Canadian-based game studio.Mon, 09 Jan 2023 00:00:00 Zcace8b7c-06b8-4456-b8be-24d8baa62077https://gowlingwlg.com/en-CA/insights-resources/client-work/2022/franchise-global-health-acquired-by-flora-growthOn December 23, 2022, Flora Growth Corp. (NASDAQ: FLGC) ("Flora"), a leading all-outdoor cultivator, manufacturer and distributor of global cannabis products and brands, closed the previously disclosed acquisition of all of the issued and outstanding shares of Franchise Global Health Inc. (TSXV: FGH) ("FGH"), a multi-national operator in the medical cannabis and pharmaceutical industry, with principal operations in Germany.Fri, 23 Dec 2022 00:00:00 Z6eef3480-7f39-4a39-b950-e4f1c0f5e736https://gowlingwlg.com/en-CA/insights-resources/client-work/2022/peloton-capital-invests-in-billyard-insuranceOn December 21, 2022, Canadian private equity firm Peloton Capital Management completed an investment in the Billyard Insurance Group portfolio of companies ("BIG") by way of a share purchase transaction.Wed, 21 Dec 2022 00:00:00 Za2c88562-8aa8-492f-bb42-15ec6b099a6dhttps://gowlingwlg.com/en-ca/insights-resources/articles/2022/dual-tax-residency-in-a-post-pandemic-worldIt is not uncommon for individuals to have more than one country in which they are considered a resident for tax purposes.  In Canada, high-net-worth individuals with a second home in a warmer jurisdiction, individuals who have obtained permanent residence status yet maintained residential ties in their country of origin, as well as employees who are on extended foreign job assignments, can all find themselves as dual residents.Tue, 20 Dec 2022 00:00:00 Zc190085d-de65-4b17-a926-16ec4046438dhttps://gowlingwlg.com/en-ca/insights-resources/articles/2022/rectification-addressing-adverse-tax-consequencesA recent decision of the Ontario Court of Justice demonstrates the restricted scope for rectification to address adverse tax consequences. The two applicants were Sleep Country Canada Holdings Inc. and Sleep Country Canada Inc. As is typical for applications seeking rectification, the respondent was the Attorney General of Canada, effectively representing the Canada Revenue Agency, who was the only party who could be adversely impacted by the relief sought yet did not oppose the application.Tue, 20 Dec 2022 00:00:00 Zbf634106-d929-494f-aa83-20c78b447a64https://gowlingwlg.com/en-CA/insights-resources/client-work/2022/royal-london-advised-on-office-lease-to-gskOur Real Estate team has advised Royal London Asset Management (RLAM) on the lease of The Earnshaw on New Oxford Street, WC1, to GlaxoSmithKline (GSK).Thu, 15 Dec 2022 00:00:00 Z3cf92670-f38b-4d2d-9162-cb21c5da26cchttps://gowlingwlg.com/en-CA/insights-resources/client-work/2022/blended-perspectives-merges-with-contegixOn December 8, 2022, Blended Perspectives, a leading North American software sales and consulting services provider of Atlassian solutions, announced a merger with Atlassian's longest-standing partner in North America, Contegix.Thu, 08 Dec 2022 00:00:00 Ze2e6fc5b-5ee2-42b2-af62-2439d4508a60https://gowlingwlg.com/en-CA/insights-resources/client-work/2022/estancia-capital-completes-strategic-investmentOn November 29, 2022, private equity firm Estancia Capital Partners announced that it had completed a significant investment in InvestorCOM, a leading provider of software and tech-enabled compliance solutions to the asset and wealth management industry.Tue, 29 Nov 2022 00:00:00 Zfc6d22bc-7f88-402f-abc1-2791a5b101a2https://gowlingwlg.com/en-CA/insights-resources/client-work/2022/nav-canada-announces-tender-offering-of-notesOn November 25, 2022, NAV CANADA announced the final pricing of its cash tender offers to purchase, in four separate offers, a targeted Maximum Purchase Consideration of up to $125 million of the outstanding debt securities of the following four series.Fri, 25 Nov 2022 00:00:00 Z80abadcf-27a1-4fbc-8bfe-6480f484ae3bhttps://gowlingwlg.com/en-ca/insights-resources/articles/2022/cop27-and-the-subject-of-single-use-plasticsThe issue of problematic plastic waste proved an important area of discussion at the UN's Climate Summit COP27. In this article, we look at the current areas of focus internationally to help reduce plastic waste and summarise the key pieces of UK legislation relating to this subject.Mon, 21 Nov 2022 00:00:00 Z31118f75-c1a6-4518-ae54-52de8219794ahttps://gowlingwlg.com/en-ca/insights-resources/articles/2022/successful-remission-order-applicationA taxpayer request to the Canada Revenue Agency (CRA) for a remission order is generally considered a method of last resort, when all other available options to obtain tax relief have been exhausted. The CRA's website states that a remission order is a rare and extraordinary measure, which will only be considered in exceptional circumstances, and the decision to grant remission is fully at the CRA's discretionTue, 08 Nov 2022 00:00:00 Zc8af838d-d6bb-48fc-9654-b76be685400bhttps://gowlingwlg.com/en-ca/insights-resources/articles/2022/taxpayers-appeals-allowed-cra-non-complianceIn its recent decision in Choptiany, the Tax Court of Canada (TCC) granted the extraordinary relief of allowing three taxpayers' appeals, without them being considered on their merits, due to the Canada Revenue Agency's serious and repeated procedural non-compliance with the TCC's rules and previous orders.Tue, 08 Nov 2022 00:00:00 Zda030101-0d1d-4b38-a5e0-2a58ce8bc1c8https://gowlingwlg.com/en-CA/insights-resources/client-work/2022/canada-s-second-time-out-market-in-vancouverOn November 8, 2022, Time Out Market announced that it would open a location in Vancouver's Oakridge Park in late 2024.Tue, 08 Nov 2022 00:00:00 Z22c67973-87c0-4593-a99b-080aa9149545https://gowlingwlg.com/en-ca/insights-resources/articles/2022/tax-measures-announced-in-fall-economic-statementOn Nov. 3, 2022 the Government of Canada tabled its 2022 Fall Economic Statement ("FES"). This bulletin summarizes the principal business-related tax measures announced in the FES.Fri, 04 Nov 2022 21:10:00 Z1a7a2123-e232-4477-b857-097ea9fe4d83https://gowlingwlg.com/en-ca/insights-resources/articles/2022/federal-government-2022-fall-economic-statementDeputy Prime Minister and Minister of Finance Chrystia Freeland tabled the 2022 Fall Economic Statement in the House of Commons on Thursday afternoon. The Liberal government is signaling a shift in its fiscal posture with this update.Fri, 04 Nov 2022 00:00:00 Z26f7eba5-b734-4663-8a32-7f24725909cehttps://gowlingwlg.com/en-CA/insights-resources/client-work/2022/lloyd-douglas-solutions-acquired-by-syntronicOn October 3, 2022, Syntronic, a global engineering design house, announced that it had acquired Lloyd Douglas Solutions Inc. ("LDS").Mon, 03 Oct 2022 00:00:00 Zac0e06b7-7958-4f9c-84c5-3e50d310a6afhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2022/corporate-energy-team-advises-brockwell-energyOur Corporate Energy team has advised Brockwell Energy Limited on the sale of Westfield Energy Recovery Limited to Equitix, a global investor, developer and long-term fund manager of core infrastructure assets.Fri, 30 Sep 2022 11:15:00 Zb7f4cf8c-7b54-46d2-8ff7-1a4794e1d23ahttps://gowlingwlg.com/en-CA/insights-resources/client-work/2022/uncharted-software-completes-sale-of-geotimeOn September 12, 2022, PenLink, Ltd., the leading developer and provider of mission critical communications and digital evidence software for law enforcement in the US and internationally, announced that it had acquired the GeoTime product line from Uncharted Software Inc., based in Toronto, Ontario.Mon, 12 Sep 2022 00:00:00 Z7643f633-bd54-4a16-ad80-509c47448b3chttps://gowlingwlg.com/en-CA/insights-resources/client-work/2022/samuel-son-co-acquires-ramp-incOn September 9, 2022, Samuel, Son & Co., Limited ("Samuel") announced its acquisition of RAMP Inc., an industrial automation company headquartered in Waterloo, Ontario, which will operate as an integral part of the Samuel Automation Solutions Group.Fri, 09 Sep 2022 00:00:00 Z9e51b48a-408d-4060-82c4-3f6b5092be6bhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2022/peopleinsight-acquired-by-hireroadOn August 22, 2022, PeopleInsight, a provider of workplace analytics software headquartered in Ottawa, Ontario, was acquired by HireRoad, a global talent management software company based in Arlington, Virginia.Mon, 22 Aug 2022 00:00:00 Z6b60470c-cd45-4e95-8950-93b2a531d00ehttps://gowlingwlg.com/en-CA/insights-resources/client-work/2022/uni-select-acquires-maslack-supply-limitedOn August 2, 2022, Uni-Select Inc. (TSX: UNS) completed its previously announced acquisition of Maslack Supply Limited ("Maslack") and related real properties.Tue, 02 Aug 2022 00:00:00 Z2ec86df4-8dd8-44f9-905c-3a8ef217402fhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2022/khiron-completes-acquisition-of-pharmadrugOn August 2, 2022, Khiron Life Sciences Corp. (TSXV: KHRN) (OTCQX: KHRNF) (Frankfurt: A2JMZC) announced that it had completed its previously announced acquisition of Pharmadrug Production GmbH from Pharmadrug Inc. (CSE:PHRX) (OTC: LMLLF).Tue, 02 Aug 2022 00:00:00 Ze646a66c-bbc6-4c0d-8c08-35b34f3bb15bhttps://gowlingwlg.com/en-ca/insights-resources/articles/2022/expert-witness-perils-in-sr-ed-appealsPersuasive expert opinion evidence is critical in scientific research and experimental development appeals before the Tax Court of Canada.Tue, 12 Jul 2022 00:00:00 Z1a96e163-5f1b-4ea6-b2b8-8262177fb1f5https://gowlingwlg.com/en-ca/insights-resources/articles/2022/business-sales-hybrid-transactions-case-law-updateThe traditional dynamic for business sale negotiations often involves a seller wanting to sell shares of the corporation that operates the business and a buyer wanting to acquire assets. Hybrid business sale structures developed to allow for a business sale to be structured as a 'hybrid' asset sale and a share sale, often to allow a seller to make use of their lifetime capital gains exemption.Tue, 12 Jul 2022 00:00:00 Z7d1a7084-7ff6-4a8a-ae75-0cf5eff6237ahttps://gowlingwlg.com/en-ca/insights-resources/articles/2022/cers-claims-result-in-jeopardy-orderJeopardy orders are integral to the Canada Revenue Agency's collections arsenal. This article provides a general overview of jeopardy orders, reviews the Federal Court decision in 11421417 where one was granted and finally provides a practice tip to help avoid them.Tue, 12 Jul 2022 00:00:00 Z1e3e4135-1397-400d-8f91-eeb50bc1cd8ehttps://gowlingwlg.com/en-CA/insights-resources/client-work/2022/sandstorm-gold-royalties-closes-basecore-portfolioOn July 12, 2022, Sandstorm Gold Ltd. ("Sandstorm Gold Royalties", "Sandstorm" or the "Company") (NYSE: SAND) (TSX: SSL) announced the closing of the previously announced acquisition of nine royalties and one stream from BaseCore Metals LPTue, 12 Jul 2022 00:00:00 Z000ca133-cf1c-4b84-b20c-09a02a633addhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2022/cross-firm-team-advises-h-t-on-acquisitionA cross firm team has advised H&T Group plc, the UK's largest pawnbroker and growing retailer of new and pre-owned jewellery and watches on its acquisition of watch servicing and repair centre, Swiss Time Services Limited.Tue, 05 Jul 2022 08:14:00 Zc058e096-c0d9-4485-a67e-c6c70966e7fbhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2022/bonduelle-sells-65-of-bonduelle-americasOn June 30, 2022, the Bonduelle Group ("Bonduelle") announced that it had obtained the approval from US and Canadian regulatory authorities and the waiver of conditions precedent allowing it to finalize an agreement with Fonds de solidarité FTQ and Caisse de dépôt et placement du Québec ("CDPQ"), selling 65% of Bonduelle Americas Long Life ("BALL"), with an enterprise value of C$850 million (approximately €625 million), to these investors.Thu, 30 Jun 2022 00:00:00 Z33f52b52-160c-479b-977f-2f3579fc641dhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2022/glia-acquires-finn-aiOn June 23, 2022, Glia, the leading provider of digital customer service, announced that it had acquired Finn AI, the premier AI-powered chatbot platform for banks and credit unions. The deal aims to mainstream virtual assistants for financial services companies by making Finn AI's proven conversational AI solutions an integral part of Glia's industry-leading Digital Customer Service (DCS) platform.Thu, 23 Jun 2022 00:00:00 Z9433e712-7f62-4d98-a228-ed17eab721c2https://gowlingwlg.com/en-CA/insights-resources/client-work/2022/rhi-group-sells-strategic-stake-in-reebee-to-flippOn June 22, 2022, Flipp announced the acquisition of reebee, Canada's second largest digital savings distribution channel. As part of the transaction, digital marketing investment firm RHI Group sold its strategic stake in reebee (originally acquired in 2019) to Flipp.Wed, 22 Jun 2022 00:00:00 Zae9a8b3a-289f-412e-b38d-dde9691840dchttps://gowlingwlg.com/en-CA/insights-resources/client-work/2022/nuts-for-cheese-closes-funding-roundOn June 15, 2022, Nuts For Cheese™, maker of dairy-free, plant-based, artisanal cheeses, announced a $5.35 million round of funding led by Forage Capital Partners along with highly experienced CPG veterans Mike Fata and Dror Balshine.Wed, 15 Jun 2022 00:00:00 Z4d997aaf-a447-491b-a22e-71b97a82cf2bhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2022/i-o-media-advised-on-acquisition-of-ideat-editionsFrench media group I/O Media (formerly Têtu Ventures) has acquired 100% of Ideat Editions from its founding director, Laurent Blanc. Ideat Editions owns and operates the magazines Ideat, The Good Life and Dim Dam Dom respectively and specialises in decoration and design, lifestyle, and slow life.Tue, 07 Jun 2022 00:00:00 Z36463752-bf1e-4107-a14e-7bbc4720290dhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2022/mucci-farms-target-of-strategic-investmentOn June 3, 2022, Cox Enterprises announced a significant strategic investment in Mucci Farms.Fri, 03 Jun 2022 00:00:00 Z0ca4dc0f-442a-462e-8351-75b515a322bbhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2022/leucrotta-completes-plan-of-arrangementOn May 31, 2022, Leucrotta Exploration Inc. (TSXV: LXE) completed its previously announced plan of arrangement under the Business Corporations Act (Alberta), pursuant to which Vermilion Energy Inc. acquired all of the issued and outstanding securities of Leucrotta for an aggregate consideration of approximately $500 million, excluding value assigned to the newly formed Montney company, Coelacanth Energy Inc.Tue, 31 May 2022 00:00:00 Ze7b7600f-26d5-4cfc-baa2-4ad61f121175https://gowlingwlg.com/en-CA/insights-resources/client-work/2022/aazhogan-acquires-bridge-at-international-fallsOn May 20, 2022, Aazhogan Limited Partnership ("Aazhogan"), a partnership of Rainy River First Nations and BMI Group, completed the acquisition of the international toll bridge between Fort Frances, Ontario and International Falls, Minnesota.Fri, 20 May 2022 00:00:00 Z63064a38-6189-4f17-acc6-fe4ad8f959fdhttps://gowlingwlg.com/en-ca/insights-resources/articles/2022/yao-v-the-queenYao v. The Queen affords a practical overview of how the Tax Court of Canada determines admissibility of proposed expert evidence. This article discusses the TCC's approach in that case and highlights some practical considerations for expert evidence in TCC appeals.Thu, 12 May 2022 12:00:00 Z42b1e0f0-5b8e-468c-a2eb-654c2927a477https://gowlingwlg.com/en-ca/insights-resources/articles/2022/can-corporate-director-contribute-shares-to-tfsaCanadian taxpayers can take advantage of various registered plans offered by the Government of Canada, including registered retirement savings plans and tax-free savings accounts. Taxpayers must ensure that the investments contributed to such plans are qualified investments, as set out in the Income Tax Act and its regulations.Thu, 12 May 2022 11:59:00 Zbb232bc5-0bbb-4b48-baf1-2dae1f863dedhttps://gowlingwlg.com/en-ca/insights-resources/articles/2022/cra-zeroes-in-on-intercompany-loansThe non-arm's length transactions which can be subject to Canadian transfer pricing legislation include tangible products, intangibles, intra-group services and cost-contribution agreements. Recently, however, the Canada Revenue Agency has been focusing on financial transactions, namely the interest rates on intercompany loans.Thu, 12 May 2022 11:59:00 Z20fea513-df55-4b4b-8830-d0b457cb6af4https://gowlingwlg.com/en-ca/insights-resources/articles/2022/new-mandatory-disclosure-rulesThe Income Tax Act currently includes disclosure obligations for "reportable transactions". However, the Canada Revenue Agency is finding that they are not "sufficiently robust" to respond quickly to tax risks associated with aggressive tax planning strategies.Thu, 12 May 2022 11:59:00 Z64bf11aa-9096-4a7a-ab23-f2a2f12dbaf3https://gowlingwlg.com/en-CA/insights-resources/client-work/2022/alpha-metaverse-acquires-shape-entertainmentOn May 5, 2022, Alpha Metaverse Technologies Inc. (CSE: ALPA) (FSE: 9HN0) (OTC PINK: APETF) (Alpha) announced that that it had completed its previously announced acquisition of 100% of the issued and outstanding share capital of Shape Immersive Entertainment Inc. (Shape) from all of the former shareholders of Shape.Thu, 05 May 2022 00:00:00 Za0d2bd5a-577b-4694-8c0e-89e75e1b6bedhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2022/thoughtworks-acquires-connectedOn April 27, 2022, Thoughtworks (NASDAQ: TWKS) announced its acquisition of privately-held, Canada-based Connected.Wed, 27 Apr 2022 00:00:00 Z098fa9f5-90f7-4b95-82f5-5711cff0b7f4https://gowlingwlg.com/en-CA/insights-resources/client-work/2022/halma-acquires-deep-trekkerOn April 14, 2022, Halma plc (LON: HLMA), a global group of life-saving technology companies, announced that it had acquired Deep Trekker Inc. for cash consideration of $60 million on a cash and debt free basis, funded from Halma's existing facilities.Thu, 14 Apr 2022 00:00:00 Z49c10497-dc78-4724-b7eb-f0b71cab631fhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2022/nymi-acquired-by-innomindsOn April 12, 2022, Innominds Software Inc. announced the acquisition of connected worker platform provider Nymi Inc. Nymi will become a wholly owned independent subsidiary of Innominds, continuing to operate from its Toronto, Ontario headquarters.Tue, 12 Apr 2022 00:00:00 Z16151be7-83dc-4232-b1cc-01c849c744d1https://gowlingwlg.com/en-CA/insights-resources/client-work/2022/gridiron-capital-invests-in-vertical-supply-groupOn April 12, 2022, Gridiron Capital, LLC announced an investment in Vertical Supply Group ("VSG").Tue, 12 Apr 2022 00:00:00 Zc89d5037-d9c1-4c70-858c-c087e6015122https://gowlingwlg.com/en-ca/insights-resources/articles/2022/federal-budget-2022-declining-deficits-tax-changesFederal Budget 2022 is a budget of optimism after two years of recession, pandemic, and now geopolitical instability. It speaks of the recovery of all jobs lost during the recession, the rebound of real GDP in Canada to a level higher than before the pandemic, and a booming economy.Fri, 08 Apr 2022 20:14:00 Z41cdf01f-ba99-41a3-bb62-b2dcf930dc85https://gowlingwlg.com/en-CA/insights-resources/client-work/2022/gowling-wlg-advises-weetabix-food-on-acquisitionA cross-firm team from Gowling WLG has advised Weetabix Food Company, the UK's number one breakfast brand, on its acquisition of Lacka Foods Ltd.Thu, 07 Apr 2022 00:00:00 Ze828f17c-77cb-41cd-97d7-4b4f68f566fahttps://gowlingwlg.com/en-CA/insights-resources/client-work/2022/citylitics-raises-us5-million-in-series-a-fundingOn March 29, 2022, Citylitics Inc. announced that it had raised US$5 million in a Series A round of funding. The investment was co-led by Dallas Venture Capital and Cerium Technology Ventures with participation from a number of existing investors.Tue, 29 Mar 2022 00:00:00 Z2f97c7ce-c5a2-496e-99de-abb1b674d051https://gowlingwlg.com/en-CA/insights-resources/client-work/2022/ground-lease-for-electric-vehicle-battery-plantOn March 23, 2022, officials from the Canadian federal and Ontario provincial governments announced a $4.9 billion joint venture deal between automaker Stellantis NV and battery maker LG Energy Solutions to construct Canada's first lithium-ion electric vehicle (EV) battery plant in Windsor, Ontario.Wed, 23 Mar 2022 00:00:00 Zb0b24d4b-30af-4c84-9a6f-2b49dcca7658https://gowlingwlg.com/en-CA/insights-resources/client-work/2022/ilia-beauty-target-of-cross-border-acquisitionOn March 22, 2022, Famille C, the Courtin-Clarins family private investment fund and owner of the French cosmetic group Clarins, acquired the US-based beauty brand, ILIA Beauty.Tue, 22 Mar 2022 00:00:00 Z5cdcc6cf-8aad-4d7a-9830-f53452f44d52https://gowlingwlg.com/en-CA/insights-resources/client-work/2022/savvas-completes-cross-border-acquisitionOn March 1, 2022, Savvas Learning Company announced its acquisition of Rubicon Publishing, Inc., the developer of Canada's most widely used all-digital math program.Tue, 01 Mar 2022 00:00:00 Ze5888b7c-6afe-4a29-a7d1-4e2580d0bee3https://gowlingwlg.com/en-CA/insights-resources/client-work/2022/matrixflo-acquires-stator-sales-serviceOn March 1, 2022, Matrixflo Inc. ("Matrixflo") announced that it, through a wholly-owned subsidiary, acquired 80% of the issued and outstanding shares of Stator Sales & Service Ltd.Tue, 01 Mar 2022 00:00:00 Z4f471089-dded-469d-8861-4ed29b64767ehttps://gowlingwlg.com/en-CA/insights-resources/client-work/2022/delpharm-acquires-sandoz-facilityOn March 1, 2022, Delpharm Industrie ("Delpharm") announced that it had acquired the Sandoz Canada manufacturing plant located in Boucherville, Québec, from Novartis.Tue, 01 Mar 2022 00:00:00 Z1de945d5-0484-433b-9d7f-fc42db37dd51https://gowlingwlg.com/en-CA/insights-resources/client-work/2022/routethis-announces-series-a-investment-roundOn February 22, 2022, RouteThis Inc. announced that it had raised a $25 million Series A investment round led by venture firm Inovia Capital. The round also included participation from Intel Capital, Round13, Garage Capital and Ken Miller Capital.Tue, 22 Feb 2022 00:00:00 Z31932cef-e9a0-43d9-b39b-73d24dc4cfdbhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2022/platinum-group-metals-convertible-notesOn February 11, 2022, Platinum Group Metals Ltd. (TSX: PTM) (NYSE American: PLG) (Platinum Group) announced the completion of the privately negotiated purchase and cancellation of the company's US$20 million 6 7/8% Convertible Senior Subordinated Notes.Fri, 11 Feb 2022 00:00:00 Zaa737bef-2ac7-4828-bff5-239a8f88b624https://gowlingwlg.com/en-CA/insights-resources/client-work/2022/fiera-acquires-260-million-industrial-portfolioGowling WLG advised Fiera Real Estate with respect to this transaction with a team that included Robert Hull and Edward Johnston (corporate and governance), Michael Bussmann (tax), Kirsty Strong (real estate), Ian Macdonald and Elad Gafni (competition), assisted by senior law clerks Jennifer John and Karen Slater.Thu, 10 Feb 2022 00:00:00 Z14c3580b-c3cf-4863-9761-ba36765eb6d4https://gowlingwlg.com/en-CA/insights-resources/client-work/2022/gowling-wlg-advises-gladman-on-million-saleA cross-firm team has advised the shareholders of land promoter Gladman Developments Limited (Gladman) on its £250 million sale to national sustainable housebuilder Barratt Developments.Tue, 01 Feb 2022 13:06:00 Z2b13e19d-ff71-43b7-9fe8-1a59fd6a134dhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2022/snap-one-completes-cross-border-acquisitionOn January 20, 2022, Snap One (NASDAQ: SNPO) announced it had acquired long-time distribution partner Staub Electronics, one of Canada's leading distributors of technology solutions focused on residential and commercial AV integrators, and automotive electronics installers.Thu, 20 Jan 2022 00:00:00 Z6a64b0dc-9ec9-43db-baf5-1618cbfa6489https://gowlingwlg.com/en-ca/insights-resources/client-work/2021/sol-cuisine-ltd-acquired-by-plantplus-foodsOn January 19, 2022, Sol Cuisine Ltd. (TSXV: VEG) announced the closing of its acquisition by PlantPlus Foods LLC ("PlantPlus Foods") and its wholly-owned subsidiary, PlantPlus Foods Canada Inc. (the "Purchaser") by way of a plan of arrangement under the Business Corporations Act (Ontario).Wed, 19 Jan 2022 00:00:00 Z1da81553-aece-46df-ab11-f2607fe0d354https://gowlingwlg.com/en-CA/insights-resources/client-work/2022/talan-to-acquire-createchOn January 13, 2022, Talan announced that it had entered into an agreement to acquire Createch, with the acquisition expected to close in Q1.Thu, 13 Jan 2022 00:00:00 Z8e13e8b9-e190-4507-a521-62ffae150c51https://gowlingwlg.com/en-CA/insights-resources/client-work/2022/management-buyout-of-inbox-insightGowling WLG's private equity team has advised UK SME investor Mobeus on its £17.7m investment in relation to the management buyout of B2B marketing company Inbox Insight.Wed, 12 Jan 2022 00:00:00 Z377cc385-7d8d-412a-9d63-4062b4686058https://gowlingwlg.com/en-CA/insights-resources/client-work/2021/community-tax-acquired-by-nextpoint-financialOn December 31, 2021, NextPoint Financial Inc. (TSX: NPF.U) (OTC Pink: NACQF) announced that it had acquired Community Tax LLC for approximately US$90 million in cash and stock, subject to certain closing adjustments.Fri, 31 Dec 2021 00:00:00 Zb188285b-807e-4795-ae58-2cb3e23122fahttps://gowlingwlg.com/en-CA/insights-resources/client-work/2021/rokmaster-resources-closes-non-brokered-financingOn December 30, 2021, Rokmaster Resources Corp. (TSXV: RKR) (OTCQB: RKMSF) (FSE: 1RR1) announced that it had completed a non-brokered financing for gross proceeds of $3,298,705. Pursuant to the financing, Rokmaster issued a total of 7,671,407 flow-through units, with each unit consisting on one flow-through common share and one half of a common share purchase warrant.Thu, 30 Dec 2021 00:00:00 Z3b4acebe-3b17-42e2-829c-790f91b6185dhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2021/atkore-inc-completes-cross-border-acquisitionOn December 20, 2021, Atkore Inc. announced the acquisition of Sasco Tubes & Roll Forming Inc., a manufacturer of metal framing and related products serving the electrical, mechanical, construction and solar industries, headquartered in Toronto, Ontario.Mon, 20 Dec 2021 00:00:00 Z0d6d013e-26d6-429c-a4f0-e643b7e5bfbbhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2021/hatchtank-acquired-by-numeratorOn December 20, 2021, Numerator, a data and tech company serving the market research space, announced the acquisition of HatchTank, a tech-enabled mobile qualitative survey company. The acquisition of HatchTank expands Numerator's capabilities across qualitative, quantitative, and panel-based consumer research, powered by advanced technology.Mon, 20 Dec 2021 00:00:00 Z90a58ffb-0c6e-4dc2-82c9-2608e27c8b13https://gowlingwlg.com/en-ca/insights-resources/client-work/2021/napkyn-analytics-acquired-by-kepler-groupOn December 15, 2021, Napkyn Analytics announced that it was joining Kepler Group, a global digital services provider. The deal unites two of the most data-driven firms in marketing to help clients more effectively derive consumer insights, activate digital intelligence, and accelerate business results.Wed, 15 Dec 2021 00:00:00 Z5b02b427-6c80-4e5b-ae8f-bc3f2e5e3144https://gowlingwlg.com/en-ca/insights-resources/articles/2021/onca-v-oca-whats-the-differenceAs described in our previous article, the Ontario Not-for-Profit Corporations Act, 2010 ("ONCA") entered into force on October 19, 2021.  It largely replaced the out-dated Ontario Corporations Act ("OCA"). The purpose of this article is to explore some of the differences between ONCA and the OCN to assist Ontario not-for-profit corporations to understand the impacts of this new statute on them.Mon, 13 Dec 2021 19:54:00 Zfeb4a9c9-6352-4c44-a216-eb8cf4351269https://gowlingwlg.com/en-ca/insights-resources/client-work/2021/nu-tech-acquired-by-reliance-steel-aluminumOn December 13, 2021, Reliance Steel & Aluminum Co. (NYSE: RS) announced that it had acquired Nu-Tech Precision Metals Inc. ("Nu-Tech"), a custom manufacturer of specialty extruded metals, fabricated parts and welded components.Mon, 13 Dec 2021 00:00:00 Ze81e6e7b-4621-4b44-a3a5-cf5fa012b8aahttps://gowlingwlg.com/en-CA/insights-resources/client-work/2021/xlcubed-limited-xl3-holdings-ltd-advised-on-saleOur corporate and tax teams have acted for the shareholders of XLCubed Limited on its acquisition by Canadian private company, Fluence Technologies Inc.Thu, 09 Dec 2021 00:00:00 Z0230e424-6c63-4d56-afc1-d9eb332b7362https://gowlingwlg.com/en-CA/insights-resources/client-work/2021/alectra-in-strategic-partnershipOn December 8, 2021, key mobility technology partners Alectra Utilities Inc., EnerTech and Linamar, along with Western University, announced a Memorandum of Understanding allowing for research and development in the mobility sector.Wed, 08 Dec 2021 00:00:00 Z31a719d9-8624-49f8-93f3-f2b2884e3d23https://gowlingwlg.com/en-ca/insights-resources/client-work/2021/via-capitale-acquires-via-capitale-du-mont-royalOn December 7, 2021, 9120-5583 Québec Inc. (d/b/a Via Capitale), a real estate broker operating in the province of Quebec, acquired 9034-1496 Québec Inc. (d/b/a Via Capitale du Mont-Royal), a real estate broker operating in Montréal.Tue, 07 Dec 2021 00:00:00 Z4d598473-c786-421c-9947-d14d5b9e9a04https://gowlingwlg.com/en-CA/insights-resources/client-work/2021/salazar-resources-signs-option-for-acquisitionOn December 3, 2021, Salazar Resources Limited (TSXV: SRL) (OTCQB: SRLZF) (Frankfurt: CCG.F) announced that it had entered into a mining option and shareholders' agreement with Minera Mesaloma S.A. and other arm's length parties (collectively, the Optionor), and Santos Resources Ltd. (Canco) pursuant to which Salazar Resources has the option (the Option) to acquire, indirectly by way of the acquisition of shares of Canco, of up to 100% of the Los Santos gold project located in southwest Ecuador.Fri, 03 Dec 2021 00:00:00 Z63772ca5-bb91-4dd0-b1ff-c9eff415d22fhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2021/bionorth-energy-completes-acquisitionOn December 2, 2021, BioNorth Energy Limited Partnership ("BioNorth Energy") announced it had completed its acquisition of the Fort St. James Green Energy Project located in Northern British Columbia. The new Indigenous-Industry partnership will build a sustainable clean energy operation, creating local jobs, supporting regional economic development, and meeting provincial demand for renewable power.Thu, 02 Dec 2021 00:00:00 Z18c29ac3-95a2-4597-8b78-e6c790e531d0https://gowlingwlg.com/en-CA/insights-resources/client-work/2021/feenics-target-of-key-acquisition-by-acreOn December 1, 2021, ACRE, a global leader of state-of-the-art security systems, announced its strategic acquisition of Feenics, a provider of cloud-based, enterprise class access control as a service (ACaaS) solutions.Wed, 01 Dec 2021 00:00:00 Zb308f148-3053-4800-9f9c-b8050109f6c5https://gowlingwlg.com/en-ca/insights-resources/client-work/2021/opin-digital-acquired-by-portage-cybertechOn December 1, 2021, Converge Technology Solutions Corp. (TSX: CTS) (FSE: 0ZB) (OTCQX: CTSDF), a software-enabled IT & Cloud Solutions provider, announced that its 53% owned subsidiary, Portage CyberTech Inc. had acquired OPIN Digital Inc. ("OPIN").Wed, 01 Dec 2021 00:00:00 Z1ff82fbf-d4b3-4081-a260-7b84630d1e6ahttps://gowlingwlg.com/en-ca/insights-resources/client-work/2021/via-capitale-acces-acquires-via-capitale-estrieOn November 29, 2021, 9333-0868 Québec Inc. (d/b/a Via Capitale Accès), a real estate broker operating in the province of Quebec, acquired the assets of Summum Courtier Immobilier Inc. (d/b/a Via Capitale Estrie), a real estate broker operating in the Eastern Townships of the province.Mon, 29 Nov 2021 00:00:00 Z5289b30f-95af-408f-ba70-75945ded5a05https://gowlingwlg.com/en-ca/insights-resources/client-work/2021/gowling-wlg-advises-swiss-impact-fund-quadiaFounded in 1993 and located in Versailles, the Institut supérieur de l'environnement (ISE) has pioneered the higher education in France in the environment and sustainable development sectors.Fri, 26 Nov 2021 00:00:00 Zad501129-0df2-47af-88cf-2eb81af35f1bhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2021/ticktrade-acquired-by-smarttradeOn November 22, 2021, smartTrade Group, a leader in multi-asset electronic trading solutions, announced the acquisition of TickTrade Systems Inc., a Toronto-based technology firm providing next-generation FX trading and payments SaaS solutions for financial institutions.Mon, 22 Nov 2021 00:00:00 Z3f5531cf-afc5-4d94-91e7-215af2051dachttps://gowlingwlg.com/en-ca/insights-resources/client-work/2021/mineros-s-a-lists-shares-on-tsxOn November 19, 2021, Mineros S.A. (TSX: MSA) (CB: MINEROS) became the first Latin American company to directly list its common shares on the Toronto Stock Exchange ("TSX"), and the first Colombian company with shares listed on both the Colombian Stock Exchange (Bolsa de Valores de Colombia – "BVC") and the TSX. Mineros closed its Canadian initial public offering for gross proceeds of approximately US$20 million.Fri, 19 Nov 2021 00:00:00 Z6c8e27f5-4155-48ee-b3e1-8752e1e8aef5https://gowlingwlg.com/en-CA/insights-resources/client-work/2021/atmofizer-closes-rto-with-vaxxinatorOn November 15, 2021, Atmofizer Technologies Inc. (formerly Consolidated HCI Holdings Corporation) ("Atmofizer") announced the closing of its previously announced reverse takeover transaction (the "RTO") with Vaxxinator Enterprises Inc. ("Vaxxinator").Mon, 15 Nov 2021 00:00:00 Z844497ad-178a-42d0-bb86-205407adc38ehttps://gowlingwlg.com/en-ca/insights-resources/articles/2021/filing-service-complaint-craTaxpayers being audited by the Canada Revenue Agency (CRA) are not likely to describe the experience as pleasant. After all, the CRA's main goal during an audit is to uncover errors with the taxpayer's filings, which would result in the taxpayer owing money.Tue, 02 Nov 2021 00:00:00 Zc2308241-b2d5-403e-a99f-3c29183a9c6chttps://gowlingwlg.com/en-ca/insights-resources/articles/2021/cra-disclosure-program-top-10-takeawaysThe publication of the so-called Pandora Papers is the biggest tax haven data leak in history. As with the Panama and Paradise Papers leaks that preceded it, extensive media reports on the Pandora Papers essentially allege that the ultra-wealthy use offshore tax havens to avoid paying taxes and question whether the line has been crossed from legal tax avoidance to illegal tax evasion. Time will tell, however, whether this is more smoke than fire.Tue, 02 Nov 2021 00:00:00 Zb4c35f54-5745-467e-b9f7-d2cc20b57909https://gowlingwlg.com/en-ca/insights-resources/articles/2021/rectification-prospects-common-sense-compassionThe compelling and sympathetic facts in Glenmac were not sufficient to dissuade the Alberta Court of Queen's Bench from applying a strict interpretation of the Supreme Court of Canada's rectification guidance from Fairmont Hotels. The Alberta Court's dismissal of the rectification application is disappointing, but not entirely unexpected given the current rigors of the legal test. However, as discussed below, whether in the circumstances the strict application of Fairmont Hotels achieved a just outcome is questionable.Tue, 02 Nov 2021 00:00:00 Z7d34e3c0-8f03-4a86-bed9-c1559a123ccehttps://gowlingwlg.com/en-CA/insights-resources/client-work/2021/avalara-completes-cross-border-acquisitionOn November 2, 2021, Avalara, Inc. (NYSE: AVLR) announced its cross-border acquisition of 3CE Technologies, Inc.Tue, 02 Nov 2021 00:00:00 Zee711f49-6bd4-4a4d-a236-ae490ad638d1https://gowlingwlg.com/en-ca/insights-resources/client-work/2021/firm-capital-28-76-million-bought-deal-financingOn November 1, 2021, Firm Capital Mortgage Investment Corporation announced that the Corporation had closed the previously announced bought deal public offering of common shares for gross proceeds of $28,758,510.Mon, 01 Nov 2021 00:00:00 Zaf0f1f32-e260-4f15-97d0-5a47ac743df3https://gowlingwlg.com/en-CA/insights-resources/client-work/2021/forward-water-technologies-reverse-takeoverOn October 20, 2021, Hope Well Capital Corp. (the "Company") acquired all the issued and outstanding shares of Forward Water Technologies Inc. (the "Target") by way of a three-cornered amalgamation of the Target and a wholly-owned subsidiary of the Company and issued 66,076,700 common shares in the capital of the Company to the shareholders of the Target. The Resulting Issuer is classified as a Tier 2 Industrial Issuer and operates under the name Forward Water Technologies.Wed, 20 Oct 2021 00:00:00 Zcf104035-f236-48ea-9c06-dfbf2bbd99b9https://gowlingwlg.com/en-ca/insights-resources/articles/2021/how-not-to-manage-cra-audit-amdocs-decisionDuring any type of tax dispute resolution process, a taxpayer's priority should always be to meet the deadlines prescribed by the relevant legislation.Tue, 28 Sep 2021 00:00:00 Zadab0c00-ef9e-480e-a56c-8145081e3c72https://gowlingwlg.com/en-ca/insights-resources/articles/2021/section-160-liability-damis-propertiesIn Damis Properties Inc. v. The Queen, the Tax Court of Canada (TCC) found subsection 160(1) of the Income Tax Act inapplicable because the appellants and their former subsidiaries were dealing at arm's length at the time of the transfer of the subject property.Tue, 28 Sep 2021 00:00:00 Zebb64704-7b08-43e8-9108-7a42cf477e58https://gowlingwlg.com/en-ca/insights-resources/articles/2021/rescission-decision-lacks-precisionThe remedies of rescission and rectification were unavailable to the taxpayers in the Alberta application RJ McLeod Investments Inc. v McLeod. The McLeod judgment includes common themes and highlights ongoing problems in four kinds of matters.Tue, 28 Sep 2021 00:00:00 Zcb0a71ea-74cc-41f7-896c-6c7549192702https://gowlingwlg.com/en-ca/insights-resources/articles/2021/voluntary-disclosures-program-update-new-normalThe Canada Revenue Agency voluntary disclosures program (VDP) has been around for decades.Tue, 28 Sep 2021 00:00:00 Z04286def-d8dd-4f2d-be87-0342aae76ab8https://gowlingwlg.com/en-CA/insights-resources/client-work/2021/libertyhill-closes-capital-raise-and-investmentOn September 23, 2021, LibertyHill Realty Partners Inc. ("LibertyHill") closed its first limited partnership equity investment of $10,701,000 to acquire and oversee the development of a prime parcel of land located in Vaughan, Ontario. Together with its developer partner, Caliber Homes Inc., the project intends to develop the land into a low-rise residential community consisting of 70 modern freehold townhomes.Thu, 23 Sep 2021 00:00:00 Z95c7d79d-6e4e-469a-808e-c57c25372184https://gowlingwlg.com/en-ca/insights-resources/client-work/2021/hinge-health-completes-cross-border-acquisitionOn September 17, 2021, Hinge Health, Inc., announced its cross-border acquisition of wrnch, Inc., as a result of which Hinge Health now has the largest computer vision team in digital health.Fri, 17 Sep 2021 00:00:00 Zea71d748-5ed6-4a35-992e-5dab4e6c93dehttps://gowlingwlg.com/en-ca/insights-resources/articles/2021/ontario-not-for-profit-corporations-act-2010At last, the Government of Ontario has announced that the Ontario Not-for-Profit Corporations Act, 2010 ("ONCA") will enter into force on October 19, 2021 - the same day the new Ontario Business Registry is set to launch.Tue, 14 Sep 2021 00:00:00 Z7c36cd7b-7aa6-4b24-9553-cdf15c621b5ehttps://gowlingwlg.com/en-ca/insights-resources/client-work/2021/firm-capital-completes-bought-deal-financingOn September 3, 2021, Firm Capital Mortgage Investment Corporation (TSX: FC) announced that it had closed its previously announced public offering of $40 million aggregate principal amount of 5.00% convertible unsecured subordinated debentures due September 30, 2028 of the Corporation. The underwriters subsequently exercised their over-allotment option in full, resulting in the issue of an additional $6 million aggregate amount of debentures.Fri, 03 Sep 2021 00:00:00 Z797a64d8-1c27-45d4-9902-7d455d364726https://gowlingwlg.com/en-CA/insights-resources/client-work/2021/cai-capital-partners-invests-in-ats-servicesOn September 1, 2021, CAI Capital Partners, a Vancouver-based private equity firm, announced that it had closed an investment in ATS Services Ltd. ("ATS"), a leader in the aviation communication services and meteorological observations industry in Canada.Wed, 01 Sep 2021 00:00:00 Zf0a9128a-49fb-4dd3-9a26-67412fd7c449https://gowlingwlg.com/en-ca/insights-resources/client-work/2021/terminix-acquires-environmental-pest-controlOn September 1, 2021, Terminix Canada acquired Environmental Pest Control headquartered in Newmarket, Ontario.Wed, 01 Sep 2021 00:00:00 Zdd70e021-b085-443e-accf-cfa93ecc673dhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2021/hire-technologies-completes-acquisitionOn August 27, 2021, HIRE Technologies Inc. (TSXV: HIRE) ("HIRE") completed the acquisition of Leaders and Co., Consulting in Governance and Leadership Inc. ("Leaders"), a premier executive search firm with clients across Canada, strong national and international alliances, and a leading Diversity and Indigenous recruitment practice.Fri, 27 Aug 2021 00:00:00 Ze890ba7e-8cc5-467a-97c7-203c5e243b69https://gowlingwlg.com/en-CA/insights-resources/client-work/2021/crawford-company-acquires-edjusterOn August 23, 2021, Crawford & Company® (NYSE: CRD-A and CRD-B) announced that it had acquired edjuster Inc., a technology-driven field and desktop contents claims handling solutions company.Mon, 23 Aug 2021 00:00:00 Zab908704-9144-4660-8969-0851bf450df2https://gowlingwlg.com/en-CA/insights-resources/client-work/2021/kumocare-acquired-by-neupath-healthOn August 17, 2021, NeuPath Health Inc. (TSXV: NPTH) announced that it had closed the previously announced acquisition of KumoCare, pursuant to which NeuPath purchased 100% of the issued and outstanding shares of Aidly Inc. and KumoCare Peel York Inc., the owners of KumoCare.Tue, 17 Aug 2021 00:00:00 Ze977e77e-e657-4c1a-94a0-23fb48028fb9https://gowlingwlg.com/en-CA/insights-resources/podcasts/2021/best-practices-for-crypto-asset-tax-reportingIn Canada, we are seeing an increased awareness amongst crypto investors and traders as to their Canadian tax reporting obligations.Mon, 09 Aug 2021 13:27:00 Zb5b8260b-5e22-4083-b0e6-6974dda1be40https://gowlingwlg.com/en-ca/insights-resources/client-work/2021/the-bountiful-company-sells-core-brands-to-nestleOn August 9, 2021, Nestlé Health Science announced the successful completion of its previously announced acquisition of the core brands of The Bountiful Company. The Bountiful Company is the number one pure-play leader in the highly attractive and growing global nutrition and supplement category.Mon, 09 Aug 2021 00:00:00 Zea8da3ad-c262-4807-87e7-fe280eca80d2https://gowlingwlg.com/en-CA/insights-resources/podcasts/2021/tax-in-a-post-pandemic-workplaceAnna Fletcher is joined by corporate finance and tax partner Zoe Fatchen to discuss the tax issues employers should be thinking about in a post-pandemic workplace.Thu, 05 Aug 2021 10:54:00 Zbd12dbeb-2a00-41ba-8b1a-e5983b721e0fhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2021/cpc-pumps-acquired-by-atlas-copcoOn August 5, 2021, Atlas Copco announced that it had acquired CPC Pumps.Thu, 05 Aug 2021 00:00:00 Z40c04c2e-0e6b-4b44-8e28-451061847b15https://gowlingwlg.com/en-ca/insights-resources/articles/2021/tpm-17-and-transfer-pricing-considerationsTPM-17 outlines the CRA's guidance on the treatment of government assistance and confirms the CRA's policy.Tue, 13 Jul 2021 02:44:00 Zde9eff3b-6835-4ca2-bd6d-2c3038debc29https://gowlingwlg.com/en-ca/insights-resources/articles/2021/canada-s-apa-program-an-overviewCanada's APA is an arrangement between the Canada Revenue Agency ("CRA") and the taxpayer that covers specific transactions between the taxpayer and related non-resident entities.Tue, 13 Jul 2021 02:43:00 Zc3ab50f9-6d3b-4be1-83c7-89f07b13386chttps://gowlingwlg.com/en-ca/insights-resources/client-work/2021/silverline-acquires-shift-crmOn July 7, 2021, Silverline CRM ("Silverline"), a digital transformation consultancy headquartered in New York City, announced that it had acquired Shift CRM, a Toronto-based company specializing in building solutions on the Salesforce platform for media and entertainment organizations. Financial terms of the transaction were not disclosed.Wed, 07 Jul 2021 00:00:00 Z8dbf9c86-7b86-4140-b5ca-dd5b0897c581https://gowlingwlg.com/en-CA/insights-resources/client-work/2021/plantx-completes-acquisition-of-liv-marketplaceOn June 25, 2021, PlantX Life Inc. (the "Company" or "PlantX") (CSE: VEGA) (Frankfurt: WNT1) (OTCQB: PLTXF) announced that the Company, through its wholly-owned subsidiary, New Deli Hillcrest LLC, had completed its previously announced transaction to acquire certain assets of LIV Marketplace LLC for an aggregate purchase price of US$3,246,938.73.Fri, 25 Jun 2021 00:00:00 Zed7746a1-c318-4f02-b855-7cce52bcdf14https://gowlingwlg.com/en-CA/insights-resources/on-demand-webinars/2021/taxation-of-tech-2021-outlookCurious about new developments in the taxation of tech? This engaging webinar brings together a panel of tax experts from Canada, the UK, France, Mexico and the US to discuss current and upcoming trends in this space.Wed, 23 Jun 2021 00:00:00 Zff09a9c5-12a3-4be2-82a9-235df938fdcbhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2021/adcore-closes-marketed-offering-of-unitsOn June 17, 2021, Adcore Inc. ("Adcore" or the "Company") (TSX: ADCO) (FSE: ADQ) closed a marketed offering of units of the Company for gross proceeds of $4,123,000.Thu, 17 Jun 2021 00:00:00 Z24bec7f6-f505-44d0-95db-8f8abb2fbda3https://gowlingwlg.com/en-CA/insights-resources/client-work/2021/coinsquare-ltd-in-a-sale-of-sharesOn June 4, 2021, Mogo Inc. acquired 5.4 million common shares of Coinsquare Ltd., Canada's leading digital asset trading platform, increasing its ownership in Coinsquare from 19.9% to approximately 37%, for total aggregate consideration of $48.6 million, satisfied through the issuance of an aggregate of 5,080,876 common shares of Mogo.Fri, 04 Jun 2021 00:00:00 Z8c0ae24f-a0c1-46d8-a732-031e5fc3caf3https://gowlingwlg.com/en-ca/insights-resources/client-work/2021/well-health-to-acquire-myhealthOn June 4, 2021, WELL Health Technologies Corp. (TSX: WELL) ("WELL") entered into a definitive share purchase agreement to acquire all of the issued and outstanding shares of MyHealth Partners Inc. ("MyHealth") for a total transaction value of up to $266.3 million.Fri, 04 Jun 2021 00:00:00 Z8ba66f38-6620-4837-a18d-a15305146741https://gowlingwlg.com/en-ca/insights-resources/articles/2021/budget-2021-tax-administration-enforcement-measureThe government declared that Federal Budget 2021 ("Budget 2021") is about finishing the fight against COVID-19 and creating prosperity for Canadians in the decades to come. Supporting this stated objective are new and enhanced tax administration and enforcement measures targeted at increasing tax revenues, including strengthening mandatory disclosure rules, proposed new measures to combat international tax avoidance, tackling tax evasion, aggressive tax avoidance and schemes to avoid collections, as well as enhanced Canada Revenue Agency ("CRA") audit powers.Thu, 27 May 2021 00:00:00 Z21ef3fcf-56a8-4e1f-ac0e-568dedd6c9b9https://gowlingwlg.com/en-ca/insights-resources/articles/2021/tax-court-affirms-expert-witnesses-know-businessIn Allegro Wireless the Tax Court of Canada ("TCC") highlighted that, to qualify as an expert, a witness must be able to demonstrate sufficient knowledge of the business and the factual foundation for the tax dispute before the TCC.Thu, 27 May 2021 00:00:00 Z7e6e2c9a-ece5-4c34-93a5-d55229242e35https://gowlingwlg.com/en-ca/insights-resources/client-work/2021/plantx-completes-acquisition-of-new-deliOn May 27, 2021, PlantX Life Inc. ("PlantX" or the "Company") (CSE: VEGA) (FRA: WNT1) (OTCQB: PLTXF) announced that the Company, through its wholly-owned subsidiary, PlantX Lifestyle USA Inc., had completed its previously announced transaction to acquire all of the issued and outstanding membership interests of MK Cuisine Global LLC's ("MKC") Plant-Based Deli, LLC ("New Deli").Thu, 27 May 2021 00:00:00 Z54a13da1-b37f-41f2-93de-e022fcbc2150https://gowlingwlg.com/en-ca/insights-resources/client-work/2021/estee-lauder-increases-ownership-in-deciemOn February 23, 2021, The Estée Lauder Companies Inc. (NYSE: EL) ("ELC") announced that it had entered into an agreement to increase its investment in DECIEM Beauty Group Inc. ("DECIEM").Tue, 18 May 2021 00:00:00 Z1a345329-bef4-4628-b0ce-d6e399e8b9fahttps://gowlingwlg.com/en-ca/insights-resources/articles/2021/new-residential-property-developer-taxThe residential property developer tax ('RPDT') is proposed to be a new super-tax targeted specifically at the residential property sector. Our tax team goes into the details in this article.Mon, 17 May 2021 08:55:00 Z25747413-2a98-44f5-a2c6-ffdbb3dadf00https://gowlingwlg.com/en-ca/insights-resources/client-work/2021/nfu-mutual-advised-on-major-logistics-network-dealA team of real estate experts from international law firm Gowling WLG has advised NFU Mutual on its investment in £100 million worth of new warehousing, equating to six new logistics facilities throughout the UK.Wed, 12 May 2021 00:00:00 Zf5d274ba-95c6-4504-9522-1740b092cf91https://gowlingwlg.com/en-CA/insights-resources/client-work/2021/gowling-wlg-advises-cairngorm-on-health-dealGowling WLG has advised private equity firm Cairngorm Capital Partners LLP on its acquisition of E-zec Medical Transport Services (E-zec), England's largest independent provider of Non-Emergency Patient Transport Services (NEPTS).Tue, 11 May 2021 00:00:00 Z3bfc382d-de1e-4b8d-bcff-3aaa70324fb0https://gowlingwlg.com/en-ca/insights-resources/client-work/2021/gowling-wlg-advises-on-the-sale-of-rebound-returnsA team of experts from the international law firm Gowling WLG has acted for the selling shareholders on the sale of retailer returns logistics platform ReBOUND Returns to The Reconomy Group, a leading provider of technology-enabled services to drive the circular economy.Tue, 11 May 2021 00:00:00 Z8e3282c9-5d39-474c-b969-14c034754914https://gowlingwlg.com/en-ca/insights-resources/client-work/2021/synergy-completes-three-cornered-amalgamationOn May 7, 2021, Synergy Disc Replacement Inc. ("SDRi ") completed a three-cornered amalgamation with its subsidiary SDRi Surgical Solutions Canada Inc. ("SDRi Subco") and Synergy Spine Solutions Inc. ("S3"). Pursuant to the transaction, S3 acquired all of the issued and outstanding securities of SDRi in exchange for securities of S3.Fri, 07 May 2021 00:00:00 Z38f1a094-fd5a-46f7-b25a-68587bae3de9https://gowlingwlg.com/en-ca/insights-resources/client-work/2021/terminix-acquires-division-of-citron-hygieneOn April 30, 2021, Terminix Canada Ltd. acquired the pest control division of Canada-based Citron Hygiene, including employees and assets in Canada, the US and the UK. As a result of the acquisition, Terminix Canada has become the country's third largest pest management company.Fri, 30 Apr 2021 00:00:00 Z76b1f21e-14e7-448c-8111-5c3e01a2bd30https://gowlingwlg.com/en-CA/insights-resources/client-work/2021/jmb-crushing-systems-completes-restructuringOn May 1, 2020, JMB Crushing Systems Inc. ("JMB") and its wholly owned subsidiary 2161889 Alberta Ltd. ("216") sought and obtained an initial order from the Court of the Queen's Bench of Alberta under the Companies' Creditors Arrangement Act R.S.C. 1985, c. C-36, as amended ("CCAA").Tue, 27 Apr 2021 00:00:00 Z0381168a-1fbf-4a83-b7b7-6182085d435ahttps://gowlingwlg.com/en-CA/insights-resources/client-work/2021/lobe-sciences-enters-into-joint-ventureOn April 26, 2021, Lobe Sciences Ltd. entered into an agreement with VPI and certain industry-leading pioneers with respect to the joint design, development and commercialization of a new psychedelic/virtual experience pod – the KrysalisTM Pod.Mon, 26 Apr 2021 00:00:00 Z91a53725-723d-42bf-b28d-84af79d2a2f6https://gowlingwlg.com/en-CA/insights-resources/client-work/2021/30-million-professional-services-acquisitionA multi-skilled team of experts from Gowling WLG has advised law firm Memery Crystal LLP on its sale to AIM-listed professional services group RBG Holdings plc for a total of £30 million.Wed, 21 Apr 2021 00:00:00 Zc04d97ce-5afb-4f43-a54b-6b2626c5fecdhttps://gowlingwlg.com/en-ca/insights-resources/articles/2021/budget-2021-canada-covid-19-recovery-budgetIn Federal Budget 2021 (Budget 2021) the Minister of Finance celebrates a projected federal deficit of $354 billion for 2020/2021, being significantly lower than the government's earlier forecast of the deficit. Only in a COVID-19 world would such an enormous deficit be considered a success.Tue, 20 Apr 2021 10:42:00 Zd8f30c44-dba2-4704-a004-9e2c3ee190adhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2021/luminate-capital-partners-makes-investmentOn April 20, 2021, Luminate Capital Partners, a private equity firm focused on enterprise software, announced a strategic growth investment in Axonify, a leader in frontline employee training software.Tue, 20 Apr 2021 00:00:00 Zb1dabeba-53ec-456d-9a96-83c65484c974https://gowlingwlg.com/en-ca/insights-resources/client-work/2021/sale-of-yotel-london-clerkenwellGowling WLG has acted for administrators Sandra Mundy and Tom Russell of James Cowper Kreston on the sale of YOTEL London Clerkenwell to LGIM Real Assets, for £70 million.Tue, 20 Apr 2021 00:00:00 Zb741ecb7-8ef9-4962-9571-e45ee50ac806https://gowlingwlg.com/en-ca/insights-resources/client-work/2021/coinsquare-announces-closing-of-investment-by-mogoOn April 16, 2021, Coinsquare Ltd., Canada's leading digital asset trading platform, announced the closing of the previously announced strategic investment in Coinsquare by Mogo Inc., a TSX and NASDAQ-listed digital payments and financial technology company.Fri, 16 Apr 2021 00:00:00 Z461926a5-731e-4955-82b4-4109ac1717b5https://gowlingwlg.com/en-CA/insights-resources/client-work/2021/leucrotta-completes-bought-deal-financingOn March 31, 2021, Leucrotta Exploration Inc. (TSXV: LXE) ("Leucrotta") announced that it had closed its previously announced upsized bought deal financing of units for gross proceeds of $30,000,080.Wed, 31 Mar 2021 00:00:00 Z5b69ec1b-3056-4910-9025-6b3d34b2e30dhttps://gowlingwlg.com/en-ca/insights-resources/articles/2021/quebec-budget-2021-2022-investment-reliefAs expected, the Québec Budget 2021-2022 is focused heavily on re-launching the Québec economy, supporting small businesses impacted by the pandemic and encouraging investment to accelerate technology adoption. Towards this goal, the Government is strengthening several tax measures aimed at the technology sector.Tue, 30 Mar 2021 00:00:00 Z0a5e0602-acb9-46d3-b92c-4124e56dd85ahttps://gowlingwlg.com/en-CA/insights-resources/client-work/2021/ametek-acquires-crank-softwareOn March 29, 2021, AMETEK, Inc. (NYSE: AME) announced that it had acquired Crank Software Inc.Mon, 29 Mar 2021 00:00:00 Zff2e051f-dcf8-405c-9da6-2b4e5cf77e7ehttps://gowlingwlg.com/en-ca/insights-resources/client-work/2021/gowling-wlg-advises-dore-hold-co-limitedGowling WLG's Energy team has advised Dore Hold Co Limited on the acquisition of Chalkhill Energy Life Holdings Limited, which holds a 96MWp portfolio of c.50 solar photovoltaic (SPV) assets.Mon, 29 Mar 2021 00:00:00 Z6a1ca840-b197-48ec-8d8d-f902f2c965d1https://gowlingwlg.com/en-ca/insights-resources/client-work/2021/gowling-wlg-advises-nabuh-energy-on-british-gasGowling WLG's Energy team has advised Nabuh Energy, a UK based energy supplier headquartered in Sheffield, on the sale of its business and assets to British Gas, which forms part of the Centrica group.Tue, 23 Mar 2021 00:00:00 Z7a658693-fdb8-4463-b777-c7820264ecf8https://gowlingwlg.com/en-CA/insights-resources/client-work/2021/sabina-bought-deal-financing-and-private-placementOn March 16, 2021, Sabina Gold & Silver Corp. (TSX: SBB) (OTCQX: SGSVF) reported that it had closed a bought deal financing with a syndicate of underwriters co-led by BMO Nesbitt Burns Inc. and RBC Dominion Securities Inc. and including Sprott Capital Partners LP, under which the underwriters bought 18,000,000 common shares of Sabina for gross proceeds of approximately $35.1 million.Mon, 22 Mar 2021 00:00:00 Z391c795f-2aa5-4227-a957-0b0d46eddfd1https://gowlingwlg.com/en-ca/insights-resources/client-work/2021/imc-closes-acquisition-of-trichomeOn March 18, 2021, IM Cannabis Corp. ("IMC") (CSE: IMCC) (NASDAQ: IMCC) announced the closing of its acquisition of Trichome Financial Corp. ("Trichome"), previously announced on December 30, 2020.Thu, 18 Mar 2021 00:00:00 Zb3f2d80b-84cd-44e3-b31d-188ec47978bahttps://gowlingwlg.com/en-ca/insights-resources/client-work/2021/hic-completes-social-bond-financingOn March 17, 2021, HPC Housing Investment Corporation (HIC) announced that it had closed a $40 million social bond offering as part of its new Construction Lending Program, that will provide long-term financing for affordable housing projects across Canada.Wed, 17 Mar 2021 00:00:00 Zfbe28860-3d81-475c-94e0-dae891eeee34https://gowlingwlg.com/en-CA/insights-resources/on-demand-webinars/2021/buying-or-selling-a-business-in-2021Gowling WLG and BDO hosted a one-hour webinar to learn about tax optimization and valuation to improve your outcomes when buying or selling a business.Mon, 15 Mar 2021 20:15:00 Zcd15efed-6a8e-43e8-a020-1461f8931acdhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2021/west-vault-closes-stream-transactionOn March 1, 2021, West Vault Mining Inc. (WVM: TSXV) (OTCQX: WVMDF) (West Vault or the Company) announced the closing of a gold and silver Purchase and Sale Agreement (Stream Agreement) with Sprott Private Resource Streaming and Royalty Corp.Mon, 01 Mar 2021 00:00:00 Z31155fec-f17d-4bd9-b292-6905729a65adhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2021/gowling-wlg-advises-codemasters-on-945m-dealGowling WLG has advised leading video games maker Codemasters on its cash acquisition by Codex Games Limited, a wholly-owned subsidiary of US video games company, Electronic Arts Inc. ("A).Wed, 24 Feb 2021 00:24:00 Z37925388-c33e-4e10-aee2-3166e4307901https://gowlingwlg.com/en-ca/insights-resources/client-work/2021/atkore-inc-acquires-fre-composites-groupOn February 24, 2021, Atkore Inc. ("Atkore"), announced that it had acquired FRE Composites® Group, a leading manufacturer of fiberglass conduit solutions for the electrical, transportation, telecommunications and infrastructure markets.Wed, 24 Feb 2021 00:00:00 Zdf5cd1ff-95cc-4c1d-b669-61ba59a1133chttps://gowlingwlg.com/en-ca/insights-resources/articles/2021/hm-treasury-s-review-of-the-uk-funds-regimeHM Treasury (HMT) published its 'Review of the UK Funds Regime: A Call for Input' (the Call for Input) on 26 January 2021.Wed, 17 Feb 2021 09:52:00 Z49a625e1-0231-4366-9eae-3bdda4adb618https://gowlingwlg.com/en-ca/insights-resources/articles/2021/february-2021-tax-court-update-back-to-businessOn February 9, Chief Justice Rossiter of the Tax Court of Canada provided the third TCC reopening update. Here are our top ten highlights.Thu, 11 Feb 2021 00:00:00 Ze7fdbe27-621a-4d74-83ed-b8704a7dfa1bhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2021/uptake-acquires-shookiotOn February 8, 2021, Uptake announced its acquisition of ShookIOT, a leader in cloud-native data integration and integrity, strengthening its capabilities to accelerate digital transformation in asset-intensive industries.Mon, 08 Feb 2021 00:00:00 Z39c7f8ca-e93d-4cb6-b797-ed979084ea98https://gowlingwlg.com/en-CA/insights-resources/client-work/2021/platinum-group-enters-into-sales-agreementEffective February 5, 2021, Platinum Group Metals Ltd. (TSX: PTM) (NYSE American: PLG) ("Platinum Group" or the "Company") entered into an Equity Distribution Agreement with BMO Capital Markets Corp. ("BMO").Fri, 05 Feb 2021 00:00:00 Z75ac8624-7751-4926-abb6-271c60acd3bbhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2021/gowling-wlg-advises-eelpower-on-jv-with-susiGowling WLG's Energy team has advised UK energy storage developer, owner and operator Eelpower on securing a multi-asset agreement with Swiss sustainable energy infrastructure fund manager SUSI Partners.Thu, 28 Jan 2021 00:00:00 Z04542c1f-f25a-48ee-9887-956f9b0bd344https://gowlingwlg.com/en-ca/insights-resources/client-work/2021/veritas-completes-cross-border-acquisitionOn January 26, 2021, Veritas Technologies LLC, headquartered in Santa Clara, California, announced the acquisition of HubStor Inc., headquartered in Kanata, Ontario.Tue, 26 Jan 2021 00:00:00 Z1650a185-cce1-4e4b-9ff8-791d9336f368https://gowlingwlg.com/en-ca/insights-resources/articles/2021/the-main-tax-consequences-of-brexit-in-franceThe UK officially left the EU and EEA on 1st February 2020 but it took 11 months of negotiations to reach an agreement on the terms and conditions of a new "free trade" area.Fri, 22 Jan 2021 00:00:00 Z0282499b-6f74-411d-a626-dfd90154d0a5https://gowlingwlg.com/en-CA/insights-resources/client-work/2021/alectra-acquires-holland-power-servicesOn January 5, 2021, Alectra Energy Services Inc. (a division of Alectra Inc.) announced that it had completed the acquisition of Holland Power Services (HPS).Tue, 05 Jan 2021 00:00:00 Z5c159a65-c56c-4eac-b79c-32541088ac1fhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2021/wh-ireland-acquires-harpsden-wealth-managementInternational law firm Gowling WLG's corporate and finance teams advised WH Ireland on its acquisition of the entire issued share capital of Harpsden Wealth Management Limited ("Harpsden"), (the "Acquisition").Tue, 05 Jan 2021 00:00:00 Zce28f859-09f0-43b9-860f-7994e8f4a608https://gowlingwlg.com/en-CA/insights-resources/client-work/2020/emerge-acquires-trulocalEffective December 31, 2020, EMERGE Commerce Ltd. ("EMERGE") (TSXV: ECOM), a leading acquirer and operator of niche e-commerce brands, closed the acquisition of all the issued and outstanding shares of truLOCAL Inc. for a total purchase price of up to $16.8 million.Thu, 31 Dec 2020 00:00:00 Zb9176c9e-5dfa-4be7-bdbd-95b4c7489113https://gowlingwlg.com/en-CA/insights-resources/client-work/2020/rocky-mountain-equipment-completes-transactionOn December 22, 2020, Rocky Mountain Equipment Alberta Ltd. (formerly Rocky Mountain Dealerships Inc.) ("RME") (TSX: RME) announced the completion of its previously announced acquisition by 2223890 Alberta Ltd. ("AcquireCo"), which was implemented through a Court-approved plan of arrangement (the "Arrangement") under the Business Corporations Act (Alberta).Tue, 22 Dec 2020 00:00:00 Z700e2d5a-60d7-44e4-945f-cb3d708b2f23https://gowlingwlg.com/en-CA/insights-resources/client-work/2020/gowling-wlg-advises-st-modwen-on-solar-park-saleA cross sector team from the firm has advised one of the leading UK's developers, St Modwen, on the sale of its Baglan Bay photovoltaic park to Innova Energy.Fri, 18 Dec 2020 00:00:00 Zb4846886-eedb-4d32-8ccf-83e4e762e8f1https://gowlingwlg.com/en-ca/insights-resources/client-work/2020/expertus-technologies-acquired-by-ibmOn December 15, 2020, IBM (NYSE: IBM) announced that it had acquired Expertus Technologies Inc. ("Expertus"), strengthening IBM's portfolio as an end-to-end digital payments solution provider and advancing its hybrid cloud and AI strategy.Tue, 15 Dec 2020 00:00:00 Za73a596a-8625-4bf4-8455-d2c3788e70c1https://gowlingwlg.com/en-CA/insights-resources/on-demand-webinars/2020/brexit-ir35-and-recruitment-in-a-pandemicThis webinar covers the new IR35 legislation coming into effect next year, the effects of Brexit and how best to address its impact, to recruiting your workforce during a pandemic and minimising employee risk in your workplace once we return to the 'new normal'.Mon, 14 Dec 2020 10:43:00 Za76789a8-34fa-4cc3-86a3-48cc0afbf142https://gowlingwlg.com/en-ca/insights-resources/client-work/2020/emerge-closes-reverse-takeover-transactionOn December 8, 2020, Emerge Commerce Ltd. (TSXV: ECOM), formerly Aumento Capital VII Corporation ("Aumento"), a company incorporated under the laws of Ontario, announced the closing of the previously announced three-cornered amalgamation whereby Emerge Commerce Inc. amalgamated with a wholly-owned subsidiary of Aumento.Tue, 08 Dec 2020 00:00:00 Zc499dfdf-d397-449d-977f-ab8f448b9354https://gowlingwlg.com/en-CA/insights-resources/client-work/2020/heavenlyrx-sells-interest-in-purekana-to-purekOn December 8, 2020, PureK Holdings Corp . (the "Company") (TSXV: PKAN), formerly AF1 Capital Corp., announced that it had indirectly acquired from HeavenlyRx Ltd. a 50.1% interest in PureKana, LLC.Tue, 08 Dec 2020 00:00:00 Z809dd28a-fa57-4b12-98f4-28c7e7d43db8https://gowlingwlg.com/en-ca/insights-resources/articles/2020/2020-canadian-federal-fall-economic-statementThe Minister of Finance presented the Government of Canada's 2020 Fall Economic Statement (FES) to Parliament on November 30, 2020.  As anticipated, the FES highlighted the economic toll that the COVID-19 pandemic has taken on the Canadian economy, resulting in an anticipated deficit in excess of $380 billion. The FES included various legislative proposals, thereby resembling a form of mini-budget, understandably as the last Federal Budget was tabled in March 2019. This bulletin highlights the more significant income and sales tax proposals.Wed, 02 Dec 2020 00:00:00 Zd10065b8-e7ca-452f-a16c-e74660280c10https://gowlingwlg.com/en-ca/insights-resources/client-work/2021/platinum-group-completes-at-the-market-offeringOn November 30, 2020, Platinum Group Metals Ltd. (TSX: PTM) (NYSE American: PLG) ("Platinum Group") completed an "at-the-market" offering of common shares first announced on September 4, 2020. The offering was completed pursuant to an Equity Distribution Agreement with BMO Capital Markets Corp. ("BMO").Mon, 30 Nov 2020 00:00:00 Z0235d34b-df37-4809-ab1c-045f18bf0768https://gowlingwlg.com/en-ca/insights-resources/client-work/2020/firm-capital-mortgage-completes-financingOn November 30, 2020, Firm Capital Mortgage Investment Corporation (TSX: FC) announced that it had closed its previously announced bought deal public offering of common shares.Mon, 30 Nov 2020 00:00:00 Z376b7351-6f5d-402a-a095-ea3918cd258ehttps://gowlingwlg.com/en-ca/insights-resources/articles/2020/french-government-introduces-new-tax-creditFrench Government introduces new tax credit for landlords to waive rent paymentsMon, 16 Nov 2020 00:00:00 Z092afb2b-7691-42a0-8b91-7e002032843ahttps://gowlingwlg.com/en-CA/insights-resources/client-work/2020/gowling-wlg-advises-lincoln-rackhouseGowling WLG advises Lincoln Rackhouse on joint investment in UK data centreTue, 10 Nov 2020 00:00:00 Zadae3f23-00c7-4856-af46-d146d9d3774dhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2020/spothero-completes-acquisition-of-rover-parkingOn October 30, 2020, SpotHero, Inc., the digital parking leader in North America, completed its previously announced acquisition of Rover Parking, a leading consumer parking app in Canada. This acquisition accelerates SpotHero's market leadership position in North America, helping the company gain access to thousands of parking locations across Canada.Fri, 30 Oct 2020 00:00:00 Zc228b524-237b-4eb2-8d85-d3b6f8ca0cf4https://gowlingwlg.com/en-ca/insights-resources/articles/2020/no-elation-when-rectification-takes-a-vacationMandel was a failed attempt to seek relief from the adverse tax consequences of a reorganization. Viewed from a high level, the two applicants (Mandel and Pike) structured their holdings through family trusts, then faced a material tax liability as their 21st anniversary approached, due to the anticipated deemed realization under subsection 104(4) of the Income Tax Act (Canada).Tue, 27 Oct 2020 18:00:00 Z13731a3b-1bc7-43e6-a234-28e0113f4775https://gowlingwlg.com/en-ca/insights-resources/articles/2020/cra-operational-updateOn October 21, three senior Canada Revenue Agency officials outlined a status update on tax controversy and dispute resolution at this stage of the COVID-19 pandemic. As the presentation was not recorded, we summarized the top ten topics covered.Tue, 27 Oct 2020 18:00:00 Zb509117e-cabb-4100-8f60-7e494ec62bbehttps://gowlingwlg.com/en-ca/insights-resources/articles/2020/covid-19-just-made-transfer-pricing-more-difficultThe COVID-19 pandemic has made the lives of hundreds of millions of people around the world uncertain, wreaking havoc on all aspects of our daily lives. Governments and taxing authorities are grappling with not only how to keep the broader macroeconomy viable over the short run, but also how to bring the economy back to fiscal balance in the medium and longer term.Tue, 27 Oct 2020 18:00:00 Z0aaa3cec-706f-40a2-989b-f22a9dba9cf0https://gowlingwlg.com/en-CA/insights-resources/client-work/2020/argonaut-gold-closes-private-placementOn October 14, 2020, Argonaut Gold Inc. (TSX: AR) announced that it had closed its previously announced "bought deal" private placement of common shares in the capital of the company that will qualify as "flow-through shares" (within the meaning of subsection 66(15) of the Income Tax Act (Canada)) for aggregate gross proceeds of $11,500,149.50, including full exercise of the underwriters' option.Wed, 14 Oct 2020 00:00:00 Z2e2c93df-2a6f-4f2f-9d1b-479528463b00https://gowlingwlg.com/en-CA/insights-resources/client-work/2020/peermusic-joins-forces-with-three-companiesOn October 7, 2020, peermusic, Canada-based Premier Muzik, France-based All Right Music and Netherlands-based Global Master Rights announced that the companies were joining forces to form the global independent leader in neighbouring rights.Wed, 07 Oct 2020 00:00:00 Z0e4715d8-bf4a-4db0-966b-9c8cb6f5d00ahttps://gowlingwlg.com/en-CA/insights-resources/client-work/2020/gowling-wlg-advises-atmosclear-on-acquisitionGowling WLG has advised AtmosClear Investments on its recent solar acquisitionTue, 06 Oct 2020 00:00:00 Z415244ee-9a76-49bc-aac3-3d1e927a2eabhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2020/aga-financial-group-sells-interest-to-novacapOn October 5, 2020, Novacap announced that it had acquired an interest in AGA Financial Group Inc. ("AGA").Mon, 05 Oct 2020 17:50:00 Z059bb087-b559-4d20-9984-561231444386https://gowlingwlg.com/en-ca/insights-resources/client-work/2020/pandell-acquires-petronet-systemsOn October 5, 2020, Pandell Technology Corporation, a pioneer of Software-as-a-Service (SaaS) solutions to the energy industry, announced that PetroNet production accounting software had joined Pandell's comprehensive back-office software suite.Mon, 05 Oct 2020 00:00:00 Z1572ebb3-6413-4e6b-9f1d-8c702413d9f7https://gowlingwlg.com/en-CA/insights-resources/client-work/2021/covertech-acquired-by-balcanOn October 1, 2020, Balcan Plastics ("Balcan") acquired Covertech Fabricating Inc. ("Covertech" or the "Company").Thu, 01 Oct 2020 00:00:00 Zc939e73f-6ce0-4c45-8578-cf1d8b79d9bahttps://gowlingwlg.com/en-ca/insights-resources/client-work/2020/waterlogic-canada-acquires-corporate-water-canadaOn September 30, 2020, Waterlogic Canada Inc. acquired all of the shares of Corporate Water Canada, a point-of-use water system distributor and servicer that operates in the Greater Toronto Area.Wed, 30 Sep 2020 00:00:00 Z55f07349-a93d-4aa7-ae79-4cea9a6241b5https://gowlingwlg.com/en-CA/insights-resources/client-work/2020/simply-good-foods-sells-to-wellness-naturalOn September 29, 2020, Wellness Natural, Inc., headquartered in Toronto, Ontario, announced that it had acquired SimplyProtein®, a nutritional snacking brand previously owned by subsidiaries of The Simply Good Foods Company.Tue, 29 Sep 2020 00:00:00 Z844ca135-2625-4679-9254-a96f1a2b5728https://gowlingwlg.com/en-CA/insights-resources/client-work/2020/uberall-acquires-sweetiqOn September 29, 2020, Uberall GmbH, a global SaaS provider headquartered in Berlin, announced that it had been selected by Gannett Co., Inc. and its digital marketing subsidiary ReachLocal to become their premier provider of presence management solutionsTue, 29 Sep 2020 00:00:00 Za56fac50-b1fc-4410-a028-8a9400af4673https://gowlingwlg.com/en-ca/insights-resources/client-work/2020/red-white-bloom-closes-bought-deal-offeringOn September 24, 2020, Red White & Bloom Brands Inc. (CSE: RWB) (OTC: RWBYF) ("RWB") closed its bought deal offering of 33,350,000 units of RWB for aggregate gross proceeds of $25,012,500, which included the full exercise of the over-allotment option.Thu, 24 Sep 2020 00:00:00 Z561268dc-8caa-461c-8366-3e70426de63chttps://gowlingwlg.com/en-CA/insights-resources/client-work/2020/cooper-equipment-rentals-acquires-herc-rentalsOn September 17, 2020, Cooper Equipment Rentals Limited ("Cooper") announced that it had acquired the Atlantic Canada assets ("Herc Atlantic") of Herc Rentals Inc. ("Herc").Thu, 17 Sep 2020 00:00:00 Z36b67492-a13e-4273-a28d-e64062385470https://gowlingwlg.com/en-ca/insights-resources/client-work/2020/pamlico-capital-completes-growth-investmentOn September 16, 2020, Pamlico Capital ("Pamlico") and the management team of ISAAC Instruments Inc. ("ISAAC" or the "Company") announced that Pamlico had completed a growth investment in the Company. Co-founders Jacques DeLarochellière, David Brillon and Jean-Sébastien Bouchard will maintain significant ownership in ISAAC and will continue to manage the growth of the Company alongside its current management team.Wed, 16 Sep 2020 00:00:00 Z2c1a7d2c-35f8-49f8-9640-6cfde89603dfhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2020/zijin-mining-acquires-guyana-goldfieldsOn August 25, 2020, Zijin Mining Group Co., Ltd (SSE: 601899) (SEHK: 2899) and Guyana Goldfields Inc. (TSX: GUY) announced the completion of the previously announced statutory plan of arrangement under the Canada Business Corporations Act involving Guyana, Zijin and 12049163 Canada Inc., an indirect wholly-owned subsidiary of Zijin, following receipt of all required regulatory approvals and satisfaction of all closing conditions. Pursuant to the arrangement, Zijin acquired all of the outstanding common shares of Guyana Goldfields for cash consideration of C$1.85 for each Guyana common share, valuing Guyana Goldfields at approximately C$323 million.Tue, 25 Aug 2020 00:00:00 Z6a60bb8f-2936-412a-a0b8-81886dd76ad1https://gowlingwlg.com/en-ca/insights-resources/client-work/2020/west-vault-mining-closes-private-placementsOn August 13, 2020, West Vault Mining Inc. (WVM: TSXV) ("West Vault") closed its previously announced brokered private placement of common shares for aggregate gross proceeds of $6,348,000 including the exercise in full of the agents' over-allotment option.Thu, 13 Aug 2020 00:00:00 Zff5a5832-fcee-4b7f-b7bc-424dc28f8007https://gowlingwlg.com/en-CA/insights-resources/on-demand-webinars/2020/home-working-and-taxIn this webinar Zoe Fatchen of Gowling WLG and David Woakes of Advantage Group UK discuss Tax issues to consider in relation to remote working.Thu, 13 Aug 2020 00:00:00 Z711a7041-1166-4b26-9a5f-102054431386https://gowlingwlg.com/en-CA/insights-resources/client-work/2020/iconiq-capital-makes-strategic-growth-investmentOn July 28, 2020, Vancouver-based ecMarket Inc. dba Conexiom, the leading provider of sales order and invoice automation solutions, announced that it had received a strategic growth investment from ICONIQ Capital, LLC. ICONIQ joined existing investor, Luminate Capital, which retained a majority stake.Tue, 28 Jul 2020 00:00:00 Z46d84d92-0260-427d-91c1-4a5e52038cechttps://gowlingwlg.com/en-CA/insights-resources/client-work/2020/arden-cross-development-around-hs2-interchangeA wide range of experts from the firm are advising on the development of the 346 acre Arden Cross site.Mon, 27 Jul 2020 00:00:00 Z9adb1756-4ae5-4718-8d87-77ae66009514https://gowlingwlg.com/en-ca/insights-resources/articles/2020/flow-through-share-spending-timelines-extendedOn July 10, 2020, the Department of Finance Canada announced a proposal to extend the time that issuers of 'flow-through shares' have to incur eligible expenditures by 12 months.Wed, 15 Jul 2020 20:44:00 Ze8cf41e9-a942-4154-b001-4c2848a1b5ffhttps://gowlingwlg.com/en-ca/insights-resources/articles/2020/cews-to-be-extended-to-december-2020The Federal Government has announced the expansion of the Canada Emergency Wage Subsidy (CEWS) until December of 2020.Tue, 14 Jul 2020 12:00:00 Z31f69421-5a68-491e-b9f5-f4032941dc2ahttps://gowlingwlg.com/en-CA/insights-resources/client-work/2020/cross-river-ventures-corp-completes-ipoOn July 13, 2020, Cross River Ventures Corp. (CRVC: CSE) (“Cross River”) announced that it had completed its initial public offering (“IPO”) of common shares on the Canadian Securities Exchange (“CSE”), which included the full exercise of the over-allotment option, to raise gross proceeds of $460,000. Haywood Securities Inc. acted as Cross River’s agent on a commercially reasonable efforts basis in respect of the IPO.Mon, 13 Jul 2020 00:00:00 Z7f4688a2-9b4d-4342-b644-e62a81cac0b4https://gowlingwlg.com/en-ca/insights-resources/articles/2020/covid-19-canadian-tax-reliefOn March 18, 2020 the Federal Government announced changes to the federal tax regime to address the difficulties faced by taxpayers due to the COVID-19 crisis.Mon, 06 Jul 2020 21:37:00 Z7b70394c-dc80-4f91-8836-ad8b016c7507https://gowlingwlg.com/en-ca/insights-resources/client-work/2020/wsib-conducts-pension-plan-conversionOn July 1, 2020, Ontario's Workplace Safety and Insurance Board (WSIB) and the Ontario Compensation Employees Union converted WSIB's $3.5 billion defined benefit, single employer pension plan (SEPP) to a jointly sponsored pension plan (JSPP) that is now administered by an independent Board of Trustees.Wed, 01 Jul 2020 00:00:00 Z9efbb5e3-aeb4-4379-8242-823574e9bdf8https://gowlingwlg.com/en-ca/insights-resources/client-work/2020/north-inc-acquired-by-google-in-cross-border-dealOn June 30, 2020, North Inc., a pioneer in human-computer interfaces and smart glasses, announced that it had been acquired by Google. Financial terms were not disclosed.Tue, 30 Jun 2020 00:00:00 Zb5978751-dc47-4b60-9040-0a8eb92ac0efhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2020/paramount-gold-nevada-closes-offering-in-canadaOn June 30, 2020, Paramount Gold Nevada Corp. (NYSE American: PZG) announced that it had closed its previously announced non-brokered registered direct offering in the US and a concurrent best efforts agency offering in Canada of shares of its common stock, for gross proceeds of US$5 million. The Canadian offering was made pursuant to Paramount’s final short form prospectus filed on June 24, 2020 with the Ontario, British Columbia and Alberta Securities Commissions.Tue, 30 Jun 2020 00:00:00 Z3d8a0d10-0372-4431-9a5b-ddef6d01b2edhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2020/metalla-completes-wharf-mine-royalty-acquisitionOn June 30, 2020, Metalla Royalty & Streaming Ltd. (TSXV: MTA) (NYSE American: MTA) announced that it had completed its acquisition of a net 1.0% royalty interest on the operating Wharf mine owned by Coeur Mining, Inc. (NYSE: CDE)Tue, 30 Jun 2020 00:00:00 Z679c1adf-1bcb-4d4f-baa0-355f16e7a38fhttps://gowlingwlg.com/en-ca/insights-resources/articles/2020/cra-update-ten-things-you-need-to-knowOn June 23, two senior Canada Revenue Agency (CRA) officials outlined a status update on tax controversy and dispute resolution at this stage of the COVID-19 pandemic.Mon, 29 Jun 2020 00:00:00 Z8215f8fa-a6f1-40a5-b53f-dcebe67cb9d9https://gowlingwlg.com/en-ca/insights-resources/articles/2020/tax-court-update-on-getting-back-to-business-juneOn June 25, the Chief Justice and Associate Chief Justice of the Tax Court of Canada (TCC) provided a second reopening update. Here are our top ten highlights.Mon, 29 Jun 2020 00:00:00 Z1dc731c8-bbe1-4e50-acbc-30a960492f95https://gowlingwlg.com/en-ca/insights-resources/articles/2020/how-secure-is-a-lender-s-secured-interestConsider a scenario where a lender provides a borrower with a loan and secures that loan against the borrower's home.Mon, 29 Jun 2020 00:00:00 Zb0e49469-099e-4f09-ba61-ac8ccae4b5b8https://gowlingwlg.com/en-ca/insights-resources/client-work/2020/los-andes-copper-ltd-sells-royaltyOn June 25, 2020, Los Andes Copper Ltd. (TSXV: LA) announced that it had sold a net smelter return (NSR) royalty to Resource Capital Fund VI L.P. (RCF VI) for a total price of US$14 million.Thu, 25 Jun 2020 00:00:00 Z0906d30f-d3c3-488e-ad0c-2144cb038432https://gowlingwlg.com/en-ca/insights-resources/articles/2020/navigating-business-digitalisationDavey Brennan and Alex Brodie, partners and co-chairs of our global Tech team, recently acted as contributing editors of International Comparative Legal Guides' 2020 Digital Business publication.Wed, 10 Jun 2020 00:00:00 Z1768e04b-d84a-45ae-ba43-0d6fade9b92fhttps://gowlingwlg.com/en-ca/insights-resources/articles/2020/cra-guidance-tax-issues-from-travel-restrictionsAs a consequence of COVID-19, governments and businesses around the world have introduced travel restrictions to protect their citizens and employees.Tue, 09 Jun 2020 12:00:00 Zfc4daa0f-6b9d-4e4a-92c2-b24720269ccchttps://gowlingwlg.com/en-CA/insights-resources/client-work/2020/cardiol-therapeutics-closes-17-25m-bought-dealOn June 4, 2020, Cardiol Therapeutics Inc. (TSX: CRDL) announced the closing of its previously announced bought deal short form prospectus offering of units for aggregate gross proceeds of $17,250,000 which includes the full exercise of the over-allotment option.Thu, 04 Jun 2020 00:00:00 Z3ff2b244-4da1-492b-90f1-199940151f0ehttps://gowlingwlg.com/en-CA/insights-resources/client-work/2020/interrent-reit-closes-230-million-bought-dealOn June 4, 2020, InterRent Real Estate Investment Trust (TSX-IIP.UN) ("InterRent") announced the closing of its previously announced public offering of 15,709,000 trust units from treasury, which includes the full exercise of the over-allotment option granted to the underwriters in connection with the offering, for gross proceeds of $230,136,850.Thu, 04 Jun 2020 00:00:00 Z161e9c4d-a1d3-4b2a-8654-e6cf21ea71dchttps://gowlingwlg.com/en-ca/insights-resources/client-work/2020/sabina-gold-silver-closes-55-mil-bought-dealOn June 3, 2020, Sabina Gold & Silver Corp. (TSX: SBB) (OTCQX: SGSVF) reported that that it had completed its previously announced bought deal offering, raising gross proceeds of $55 million.Wed, 03 Jun 2020 12:00:00 Z0fe9e446-b1fc-43a1-9694-cd68710113c9https://gowlingwlg.com/en-CA/insights-resources/client-work/2020/crawford-company-sells-51-interestOn June 1, 2020, Crawford & Company (Canada) Inc. sold its 51% interest in Crawford Compliance Inc. to a third party in exchange for a note receivableMon, 01 Jun 2020 00:00:00 Zd481ea75-c97e-497f-8d0f-bd5e935a187ehttps://gowlingwlg.com/en-CA/insights-resources/client-work/2020/aleafia-health-closes-14-95-million-bought-dealOn May 29, 2020, Aleafia Health Inc. (TSX: AH) announced that it had closed its previously announced bought deal offering of units for aggregate gross proceeds of $14,950,000, which included the full exercise of the over-allotment option.Fri, 29 May 2020 00:00:00 Zb17f3f02-7129-456d-aac1-b7a14519fc7ahttps://gowlingwlg.com/en-CA/insights-resources/client-work/2020/inductiv-acquired-by-appleOn May 27, 2020, Bloomberg reported that Apple Inc. had purchased machine-learning startup Inductiv Inc., adding to more than a dozen AI-related acquisitions by Apple in the last few years.Wed, 27 May 2020 00:00:00 Z5ab77792-534e-4175-8f24-e0ebb63b742bhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2020/balmoral-resources-wallbridge-mining-companyOn May 22, 2020, Balmoral Resources Ltd. (TSX: BAR) (OTCQX: BALMF) and Wallbridge Mining Company Limited (TSX: WM) announced the completion of a plan of arrangement between the companies.Fri, 22 May 2020 12:00:00 Z4875d8e4-96b0-43bd-8f73-b07219c70e41https://gowlingwlg.com/en-ca/insights-resources/client-work/2020/mawson-resources-closes-oversubscribedOn May 20, 2020, Mawson Resources Limited (TSX: MAW) (Frankfurt: MXR) (PINKSHEETS: MWSNF) announced that it had closed its previously announced public offering of units to raise gross proceeds of $17,000,200.Wed, 20 May 2020 12:00:00 Zbf2214f7-bf2a-4f1c-ba0d-6b1300dc5a87https://gowlingwlg.com/en-ca/insights-resources/articles/2020/canadian-tax-the-new-75-wage-subsidyOn April 1, 2020, Finance Minister Bill Morneau released details regarding the Federal Government's new CEWS.Tue, 19 May 2020 17:22:00 Zcf95214b-9103-4c4c-a30f-98e58b70ad4ahttps://gowlingwlg.com/en-ca/insights-resources/articles/2020/director-liability-support-section-160-assessmentThe Queen v Colitto addressed the combined effect of two provisions that create third party liability for someone's tax debts.Tue, 19 May 2020 00:00:00 Zb7e01766-9ad3-4e76-b4c7-f48f655f2975https://gowlingwlg.com/en-ca/insights-resources/articles/2020/tax-court-update-top-ten-takeawaysOn Friday, May 15, Chief Justice Rossiter of the Tax Court of Canada provided an informative status update on the TCC during the COVID19 shutdown and preparing for eventual reopening.Tue, 19 May 2020 00:00:00 Z9c086b33-4bae-4f26-9ae7-562768742e1bhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2020/frankly-completes-business-combination-with-torqueOn May 11, 2020, Torque Esports Corp., Frankly Inc., and WinView, Inc. completed their business combination, pursuant to which Torque acquired each of Frankly and WinView, creating an integrated platform dedicated to live esports, news and gaming. The combined company is called Engine Media Holdings, Inc. [Esports, News, Gaming, Interactive Network, Engagement].Mon, 11 May 2020 00:00:00 Zd36b45e5-5d4f-475a-b97d-95c93ef5e4e0https://gowlingwlg.com/en-ca/insights-resources/client-work/2020/wayside-technology-group-makes-acquisitionOn May 1, 2020, Wayside Technology Group, Inc. (NASDAQ: WSTG), an IT channel company providing innovative sales and distribution solutions, completed its acquisition of Interwork Technologies Inc. from FirePower Equity Inc.Fri, 01 May 2020 00:00:00 Z54bbd445-02fd-4b2b-9e91-c852b1e5c0aehttps://gowlingwlg.com/en-CA/insights-resources/client-work/2020/crtce-acquired-by-altmed-capitalOn April 29, 2020, AltMed Capital Corp. (AltMed) purchased 100% of the shares of the Canadian Rapid Treatment Centre of Excellence Inc. (CRTCE).Wed, 29 Apr 2020 12:00:00 Z46eeb00f-ead7-4a08-afff-9590ec3b42c3https://gowlingwlg.com/en-CA/insights-resources/client-work/2020/fiera-acquires-75-interest-in-pickering-placeOn April 27, 2020, Fiera Real Estate announced the successful acquisition of a 75% interest in 25 Pickering Place in Ottawa, Ontario (the "Property") on behalf of Fiera Real Estate CORE Fund LP (the "CORE Fund").Mon, 27 Apr 2020 00:00:00 Z3df8b1f3-9659-4bce-a34c-8bd93c6b6819https://gowlingwlg.com/en-ca/insights-resources/articles/2020/canada-emergency-wage-subsidy-calculator-availableIn an effort to assist businesses, the Federal Government passed legislation implementing the Canada Emergency Wage Subsidy (CEWS) earlier this month.Thu, 23 Apr 2020 00:00:00 Zaa8729b8-998e-4a84-9728-a935d40cea43https://gowlingwlg.com/en-ca/insights-resources/articles/2020/cra-audit-activity-the-calm-before-the-stormVery few multinational taxpayers, as well as taxing authorities, are thinking about transfer pricing as intensively as they did just a few weeks ago, with companies and the Canada Revenue Agency working, in large part, remotely.Wed, 22 Apr 2020 00:00:00 Z3f4a6210-c890-4616-b1a6-8f5ccbb4024chttps://gowlingwlg.com/en-ca/insights-resources/articles/2020/federal-court-of-appeal-blocks-crownCBS Canada confirmed that the Crown is bound by its settlement agreements with taxpayers. A deal is a deal. The case has other important ramifications for future tax disputes and is recommended reading for anyone who practices tax and tax dispute resolution.Wed, 22 Apr 2020 00:00:00 Z2a59e065-73e9-4899-9e54-dbfed0f6bbb6https://gowlingwlg.com/en-ca/insights-resources/articles/2020/taking-control-during-uncertain-timesIn this article we provide some practical tips on how best to use a slowdown in operations to prepare your business for a future M&A transaction.Thu, 16 Apr 2020 00:00:00 Z9d85caa5-ca25-4a70-bc7a-3e11306dfff2https://gowlingwlg.com/en-CA/insights-resources/client-work/2020/gowling-wlg-advises-cpcs-and-infraco-africaInternational law firm Gowling WLG has advised CPCS Transcom Ltd. and InfraCo Africa on a historic partnership to develop Liberia's first open-access commercial, modern warehousing facility and operations.Tue, 14 Apr 2020 00:00:00 Zef3f8199-f12c-4d65-b4d2-7d4c828fa3fchttps://gowlingwlg.com/en-ca/insights-resources/articles/2020/transfer-pricing-during-economic-disruptionsIn light of the potential economic downturn arising from the COVID-19 pandemic, it would be prudent for Canadian companies to consider transfer pricing matters at this time.Tue, 07 Apr 2020 19:40:00 Z52d18d86-2029-43e8-812c-0c86ef6d8d00https://gowlingwlg.com/en-ca/insights-resources/articles/2020/ir35-carry-on-preparingThe government has announced that IR35 reform, extending the IR35 tax rules to medium and large private sector businesses, is being delayed a year to 6 April 2021.Wed, 25 Mar 2020 15:52:00 Z8cb380f6-8dce-49e8-ab9c-7dab65efe894https://gowlingwlg.com/en-ca/insights-resources/articles/2020/managing-risk-covid-19-guideA guide for businesses managing the risks of COVID-19.Tue, 24 Mar 2020 00:00:00 Z38884bb7-115c-4b14-bf55-02dfc90e82b8https://gowlingwlg.com/en-CA/insights-resources/client-work/2020/curtiss-wright-completes-acquisitionOn February 28, 2020, Curtiss-Wright Corporation (NYSE: CW) ("Curtiss-Wright") acquired the stock of Dyna-Flo Control Valve Services Ltd. ("Dyna-Flo") for $81 million in cash.Fri, 28 Feb 2020 00:00:00 Z9f9833b9-6f39-436b-a4b9-683178a74858https://gowlingwlg.com/en-CA/insights-resources/client-work/2020/metalla-and-batteryone-joint-ventureOn Feb. 18, 2020, Metalla Royalty & Streaming Ltd. (TSXV: MTA) (NYSE American: MTA) announced that it had acquired a 2.0% net smelter return royalty ("NSR") on future gold production from the La Fortuna deposit and prospective exploration grounds forming part of the NuevaUnión project located in Chile. NuevaUnión is jointly owned by Newmont Corporation and Teck Resources Limited, and is one of the largest undeveloped copper-gold-molybdenum projects in the world.Tue, 18 Feb 2020 00:00:00 Z6b383dc6-7126-473b-b702-77360d41af1chttps://gowlingwlg.com/en-CA/insights-resources/client-work/2020/even-matchup-gaming-acquired-by-new-wave-esportsOn Feb. 10, 2020, New Wave Esports Corp. ("NWES") announced it had completed the acquisition of all of the issued and outstanding shares of Even Matchup Gaming Inc. ("EMG") not previously held by NWES. New Wave Esports previously held an 18% stake in EMG, an esports events production and broadcast company based in Toronto, Ontario.Mon, 10 Feb 2020 00:00:00 Ze9402184-c455-4111-924d-779023e6d123https://gowlingwlg.com/en-CA/insights-resources/client-work/2020/alectra-via-util-assist-invests-in-grid4cOn January 28, 2020, Grid4C, a worldwide leader in artificial intelligence (AI) and machine learning solutions for the energy industry, announced that Util-Assist Inc., a leading professional services and managed services company to North American utilities, had invested US$5 million in Grid4C.Tue, 28 Jan 2020 21:03:00 Za1087096-a99c-4c4a-84b6-d3ea429ed130https://gowlingwlg.com/en-ca/insights-resources/articles/2020/ir35-changes-and-automatic-enrolment-pensionsHow will 6 April 2020 changes to IR35 impact on workplace pension reform (WPR) / automatic enrolment and pension provision?Mon, 27 Jan 2020 00:00:00 Z41cbcdd1-5a8a-4d42-a593-9f08a5834399https://gowlingwlg.com/en-ca/insights-resources/articles/2020/ir35-technical-consultation-launchedOn 22 January 2020, HM Treasury launched a technical consultation on the draft secondary legislation for off-payroll working from April 2020.Thu, 23 Jan 2020 14:33:00 Zc9ee6229-a244-4747-9804-48cd744e70b5https://gowlingwlg.com/en-CA/insights-resources/client-work/2020/credit-suisse-sells-place-du-canadaOn Jan. 23, 2020, Crestpoint Real Estate Investments Ltd. announced the recent acquisition of the Place du Canada office building situated at 1010 de la Gauchetière Street West in Montréal. Crestpoint acquired a 97% interest on behalf of its investors; the remaining 3% was acquired by Redbourne, who will act as the property manager.Thu, 23 Jan 2020 00:00:00 Z2132b77d-c01a-4049-864f-c48ab2646d32https://gowlingwlg.com/en-ca/insights-resources/client-work/2020/paytah-services-acquires-fire-suppression-assetsOn January 17, 2020, Aboriginal health & safety company Paytah Services Inc. acquired certain fire suppression assets from Star Valley Oilfield Services Ltd.Fri, 17 Jan 2020 00:00:00 Z90c1f0b1-e058-4e2b-adfd-dfb338051c71https://gowlingwlg.com/en-CA/insights-resources/client-work/2020/gowling-wlg-advises-william-f1-on-wae-disposalGowling WLG has advised key client Williams F1 on its disposal of a majority interest in its subsidiary WAE, to funds controlled by EMK Capital.Mon, 13 Jan 2020 00:00:00 Ze747b832-6549-4ab5-a6a1-508af21209fdhttps://gowlingwlg.com/en-ca/insights-resources/articles/2020/ir35-review-announced-but-date-unchangedThe existing public sector restrictions and rules on off-payroll working (IR35) will be extended to medium and large private sector employers from 6th April 2020.Thu, 09 Jan 2020 11:20:00 Z23ff5c2e-c0e5-4fbe-9cef-2104197ba5e5https://gowlingwlg.com/en-CA/insights-resources/client-work/2020/canadian-hospital-specialties-acquires-carestreamOn Jan. 6, 2020, Canadian Hospital Specialties Limited ("CHS") announced the acquisition of Canadian operations of CAREstream Medical, the leader in the field of respiratory and anesthesia solutions and supplies.Mon, 06 Jan 2020 00:00:00 Zcc2cf395-259a-400b-9cbb-8181c5c59465https://gowlingwlg.com/en-ca/insights-resources/client-work/2020/laker-energy-products-sold-to-bwxtOn January 2, 2020, BWX Technologies, Inc. announced that its subsidiary BWXT Canada Ltd. had acquired Laker Energy Products Ltd.Thu, 02 Jan 2020 00:00:00 Z2290d9e9-ddfa-45f5-967b-596f056c312ehttps://gowlingwlg.com/en-CA/insights-resources/client-work/2019/iplayco-closes-plan-of-arrangementEffective December 31, 2019, Iplayco Corporation Limited (TSXV: IPC) completed a statutory plan of arrangement pursuant to section 193 of the Business Corporations Act (Alberta), involving Iplayco, its shareholders and TSL888 Investments, Inc. ("TSL").Tue, 31 Dec 2019 12:00:00 Zb99e860a-db3d-4113-aea3-13605707a978https://gowlingwlg.com/en-CA/insights-resources/client-work/2020/balmoral-resources-closes-private-placementOn Dec. 30, 2019, Balmoral Resources Ltd. (TSX: BAR) announced that it had closed its previously announced non-brokered flow-through private placement.Mon, 30 Dec 2019 00:00:00 Zca6d7ed2-48b0-49f4-a189-ec33f9f05e64https://gowlingwlg.com/en-ca/insights-resources/client-work/2019/erie-architectural-acquired-by-ykk-ap-americaOn Dec. 9, 2019, YKK AP America Inc. ("YKK AP"), a leading manufacturer of award-winning commercial facade systems and residential doors and windows, announced the acquisition of high-performance facades solutions provider, Erie Architectural Products Group Inc. ("Erie AP").Mon, 09 Dec 2019 00:00:00 Zfc48f3ad-2f83-4b13-afdd-34ea43bb3d2chttps://gowlingwlg.com/en-ca/insights-resources/client-work/2019/brixton-metals-closes-private-placement-of-sharesOn Nov. 28, 2019, Brixton Metals Corporation (TSXV: BBB) (OTCQB: BBBXF) announced the closing of its previously announced private placement of common shares and flow-through common shares to investors in Canada.Thu, 28 Nov 2019 00:00:00 Z29a31706-37e8-4f4b-be04-01cb0ecdbd66https://gowlingwlg.com/en-ca/insights-resources/articles/2019/investors-beware-is-cra-coming-after-your-tfsaA Tax-Free Savings Account ("TFSA") is a popular savings tool allowing Canadian account-holders to contribute cash, stocks, bonds and other investments, to earn investment income or realize capital gains tax-free. TFSAs can, however, become disastrous for some successful investors who, in a short time, have amassed significant wealth in their TFSAs.Tue, 26 Nov 2019 16:09:00 Z4494c9df-86da-4814-8ac9-44f4b6257352https://gowlingwlg.com/en-ca/insights-resources/articles/2019/transfer-pricing-what-s-new-in-canada-part-iiiPart III of this article, the final segment, deals with self-initiated transfer pricing adjustments and, more particularly, what has changed in this area since 2012.Tue, 26 Nov 2019 12:00:00 Z1675c508-6329-4507-8caa-720590d7867ehttps://gowlingwlg.com/en-ca/insights-resources/articles/2019/taxation-and-the-first-nations-fiscal-management-aIndigenous rights are not only about legal or political opportunity but also practical capacity. A First Nation's capacity to govern can mean the difference between the true exercise of a right and the same right existing only on paper. The ability to charge service fees and taxes can help to build reliable and ongoing own-source revenue capacity for First Nation governments.Mon, 25 Nov 2019 00:00:00 Z60034ee9-898e-45c7-aecb-dc74849f871ahttps://gowlingwlg.com/en-CA/insights-resources/client-work/2019/draganfly-inc-lists-on-cseOn Nov. 5, 2019, Draganfly Inc. (CSE: DFLY) began trading on the Canadian Securities Exchange under ticker symbol "DFLY". The company has also filed its long form non-offering final prospectus with the securities regulatory authorities in each of Saskatchewan and British Columbia to become a reporting issuer in those jurisdictions.Tue, 05 Nov 2019 00:00:00 Zc77ac017-f97c-45aa-806a-a5678e0743a4https://gowlingwlg.com/en-CA/insights-resources/client-work/2019/nexa-resource-karmin-exploration-close-arrangementOn Oct. 30, 2019, Nexa Resources S.A. (NYSE: NEXA) (TSX: NEXA) and Karmin Exploration Inc. announced that they had completed their previously announced plan of arrangement among Nexa, Karmin, Votorantim Metals Canada Inc., a wholly-owned subsidiary of Nexa, and Kar Gold Inc. ("SpinCo").Wed, 30 Oct 2019 00:00:00 Zb2d6c0f0-f271-4b65-a9ae-a4e9a1c4c91ahttps://gowlingwlg.com/en-ca/insights-resources/articles/2019/gowling-wlg-quebec-tax-fall-updateAs the fall season approaches, it is time for companies doing business or having customers in Québec to review whether certain new Québec tax measures apply to them.Mon, 28 Oct 2019 00:00:00 Zc14fa15e-7377-464e-a9e3-67f37b1e0f09https://gowlingwlg.com/en-CA/insights-resources/client-work/2019/balmoral-resources-closes-fall-placementsOn Oct. 25 and Nov. 8, 2019, Balmoral Resources Ltd. (TSX: BAR) closed the first and second tranches of its Fall 2019 non-brokered private placements of flow-through shares and non-flow-through units for aggregate gross proceeds of $3,491,396.86.Fri, 25 Oct 2019 00:00:00 Z4767b73b-fcb6-4578-8e5a-eb3e07959278https://gowlingwlg.com/en-ca/insights-resources/client-work/2019/bravo-target-safety-and-acden-announce-partnershipOn October 16, 2019, Acden and Bravo Target Safety announced the creation of Acden Bravo Target, a partnership which will provide economic and employment benefits in the Wood Buffalo region of northeastern Alberta.Wed, 16 Oct 2019 00:00:00 Z79fded76-8b4c-4b97-af2d-93d6747c79c9https://gowlingwlg.com/en-ca/insights-resources/client-work/2019/party-city-completes-174-million-saleOn Oct. 1, 2019, Party City Holdco Inc. (NYSE: PRTY), the leading party goods company by revenue in North America, announced that it had completed the previously announced sale of its Canadian retail business to Canadian Tire Corporation, Limited (TSX: CTC). Pursuant to the agreement, Canadian Tire acquired the retail business and assets of Party City's Canadian subsidiary, including 65 retail store locations in Canada, in an all-cash transaction valued at approximately $174 million.Tue, 01 Oct 2019 00:00:00 Z22090e1b-45ee-402f-ab76-cd95d51679bahttps://gowlingwlg.com/en-ca/insights-resources/articles/2019/ir35-private-sector-reformWe unpack the 'who, what and when' of the draft legislation and HMRC guidance and their potential impact on employers.Mon, 30 Sep 2019 10:35:00 Z042fd061-018d-4761-ba08-1450318f52c0https://gowlingwlg.com/en-ca/insights-resources/client-work/2019/slr-consulting-acquires-rpaOn Sept. 10, 2019, SLR Consulting ("SLR"), a global provider of environmental and advisory solutions, acquired RPA Inc., a 60-person, world-leading mining advisory business with teams in Toronto, Denver and London.Tue, 10 Sep 2019 00:00:00 Zd70954f1-76db-4a11-ad41-375b80009dcfhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2019/cummins-closes-on-its-acquisition-of-hydrogenicsOn Sept. 9, 2019, Cummins Inc. (NYSE: CMI) announced that it had closed on the previously announced cross-border acquisition of fuel cell and hydrogen production technologies provider Hydrogenics Corporation, headquartered in Mississauga, Ontario.Mon, 09 Sep 2019 00:00:00 Zaaf345ef-0ec4-4b2e-95a8-191290f8515fhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2019/mcrock-capital-launches-industrial-internetOn Aug. 30, 2019, McRock Capital held an initial closing on its second venture capital fund, McRock Fund II LP, dedicated to investing in the global trend around the Industrial Internet of Things (IoT).  For the initial closing, the new Fund reached over 80% of its targeted $100 million.Fri, 30 Aug 2019 00:00:00 Z430e5bf8-ce8b-427c-9551-ac41aa3b286dhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2019/marshangus-hospitality-group-acquires-90-of-shareOn August 30, 2019, Marshangus Hospitality Group Inc. acquired 90% of the shares of KIN Vineyards Inc. for an undisclosed consideration.Fri, 30 Aug 2019 00:00:00 Zef3c274e-3da7-4e3a-b1d5-0e8133a7592ehttps://gowlingwlg.com/en-CA/insights-resources/client-work/2019/waterlogic-canada-acquires-city-waterOn Aug. 30, 2019, Waterlogic Canada Inc. acquired all of the shares of City Water International Inc. (a bottled water supplier located in Toronto, Ontario) and its US subsidiary.Fri, 30 Aug 2019 00:00:00 Ze426ef8f-13c9-494a-af5b-f9c25dbf6191https://gowlingwlg.com/en-ca/insights-resources/articles/2019/keep-your-eye-on-the-time-timing-liability-underIn Eyeball Networks, the TCC alerted tax planners to the pitfalls of issuing and cancelling a promissory note with nominal value in the context of a tax-neutral rollover under section 85 of the ITA.Thu, 29 Aug 2019 00:00:00 Z46981d7e-da11-4837-b7ca-f45d3855e22ehttps://gowlingwlg.com/en-ca/insights-resources/articles/2019/transfer-pricing-what-s-new-in-canada-part-iiIn Part II of the article, we focus on the Canadian court decisions on transfer pricing cases that have been rendered during this period.Thu, 29 Aug 2019 00:00:00 Zf64a1f82-971c-4b42-a9c3-d6ed5b473bf8https://gowlingwlg.com/en-CA/insights-resources/client-work/2019/platinum-group-closes-financingsOn Aug. 21, 2019, Platinum Group Metals Ltd. closed a bought deal financing with BMO Capital Markets in the United States, under which it sold 8,326,957 of its common shares by way of public offering for gross proceeds of approximately US$10.4 million.Wed, 21 Aug 2019 00:00:00 Zf9f39f93-6ac9-45f8-8e81-dc4ee5faab8dhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2019/colorado-resources-acquires-buckingham-copperOn August 20, 2019, Colorado Resources Ltd. and Buckingham Copper Corp. announced that they had completed their previously announced plan of arrangement under the Business Corporations Act (British Columbia).Tue, 20 Aug 2019 00:00:00 Za670ee83-16d4-48fe-8ac4-a93a5272b2afhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2019/terraco-gold-acquired-by-sailfish-royaltyOn Aug. 19, 2019, Sailfish Royalty Corp. and Terraco Gold Corp. announced the completion of the previously announced transaction between the two companies.Mon, 19 Aug 2019 00:00:00 Z61a8794b-c9e0-4373-a7bd-6cbbddaa38e6https://gowlingwlg.com/en-ca/insights-resources/client-work/2019/draganfly-inc-closes-recapitalization-and-reverseOn August 16, 2019, Draganfly Inc. (formerly Drone Acquisition Corp.) (Draganfly) closed its recapitalization and reverse takeover transaction with Draganfly Innovations Inc.Fri, 16 Aug 2019 00:00:00 Z97dbd98b-ca21-4635-a401-3bd1504a0123https://gowlingwlg.com/en-CA/insights-resources/client-work/2019/rhi-group-and-m33-growth-make-strategic-investmentOn Aug. 8, 2019, reebee announced that RHI Group Inc. in partnership with M33 Growth, LLC, had made a significant investment in the company.Thu, 08 Aug 2019 00:00:00 Zdb9d0989-2cf2-4619-96f7-b33977a04ccdhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2019/absorb-software-completes-cross-border-acquisitionAbsorb Software is a learning technology company based in Calgary, Alberta, with global offices in London, Dublin, Shanghai, Sydney, Boston, Tampa and Salt Lake City.Wed, 07 Aug 2019 00:00:00 Zd57a36ff-9b2e-43f6-9341-d1bd1da56bcdhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2019/newlook-capital-forms-dentalook-and-8-practicesOn Aug. 6, 2019, North American private equity firm Newlook Capital Inc. announced the completion of its investment in eight dental practices in Ontario and Saskatchewan through a multi-layered corporate structure. Newlook formed Newlook Capital Dental Services Trust to raise capital for the transaction as well as for future acquisitions. Dentalook Management Co. was formed as the main acquisition vehicle and management company in respect of the dental practices acquired.Tue, 06 Aug 2019 00:00:00 Zb0f8c486-e46a-4c84-adc7-767a8ad2333dhttps://gowlingwlg.com/en-ca/insights-resources/articles/2019/recognizing-tax-implications-for-damage-awardsA recent Tax Court of Canada decision, provides a fresh reminder for lawyers to be mindful of potential tax implications of damage awards.Thu, 01 Aug 2019 00:00:00 Z5f362c07-fdbc-4448-9fbb-761afbaf84achttps://gowlingwlg.com/en-ca/insights-resources/articles/2019/hanging-by-a-threadThe British Columbia Supreme Court (BCSC) decision in Collins Family Trust v Canada (Attorney General) (Collins) grants at least a temporary reprieve for the equitable remedy of rescission in an income tax context.Wed, 31 Jul 2019 00:00:00 Zd4529ad9-c9f0-4498-ba9a-39eccf0fb524https://gowlingwlg.com/en-ca/insights-resources/articles/2019/transfer-pricing-what-s-new-in-canada-part-iGeneral Review of Transfer Pricing Developments in CanadaWed, 31 Jul 2019 00:00:00 Z5ff50fac-894c-4f58-b0f5-efe8a5adcf35https://gowlingwlg.com/en-CA/insights-resources/client-work/2019/stamford-land-acquires-8-finsbury-circusGowling WLG advises Stamford Land on the acquisition of 8 Finsbury Circus.Tue, 30 Jul 2019 00:00:00 Z2a57c49b-545d-4a61-95e8-7f2892b93576https://gowlingwlg.com/en-ca/insights-resources/articles/2019/disclosed-nominee-agreements-to-revenu-quebecEffective May 17, 2019,  all nominee agreements made as part of a transaction or series of transactions must be disclosed to Revenu Quebec within 90 days.Tue, 23 Jul 2019 00:00:00 Z02dca184-acfd-4826-9700-d606e783d59fhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2020/walker-aggregates-acquires-harold-sutherlandOn July 12, 2019, Walker Aggregates Inc., an Ontario-based construction materials company, acquired certain Ontario-based construction and aggregates companies (including Harold Sutherland Construction Inc. and H.S.C. Aggregates Ltd.) owned by Harold Sutherland.Fri, 12 Jul 2019 00:00:00 Zbff003c6-4325-4168-b29f-5663911522b9https://gowlingwlg.com/en-CA/insights-resources/client-work/2019/heavenlyrx-announces-strategic-investmentOn July 11, 2019, HeavenlyRx Ltd. announced a significant investment in Jones Soda Co. (OTCQB: JSDA), a leading premium soda-maker based in Seattle, Washington.Thu, 11 Jul 2019 00:00:00 Zc9df000c-e500-4731-934e-837a547d31aahttps://gowlingwlg.com/en-CA/insights-resources/client-work/2019/interrent-reit-closes-201-million-bought-dealOn July 9, 2019, InterRent Real Estate Investment Trust (TSX: IIP.UN) announced the closing of its previously announced public offering of 14,375,000 trust units from treasury, including the full exercise of the over-allotment option granted to the underwriters, for gross proceeds of $201,250,000.Tue, 09 Jul 2019 00:00:00 Zcd9d6cd8-1b4c-4fd4-961f-b2ae8d199d17https://gowlingwlg.com/en-ca/insights-resources/articles/2019/proposed-amendments-to-the-stock-option-rulesOn June 17, 2019, the Minister of Finance tabled a Notice of Ways and Means Motion that contains the proposed, which are intended to be effective for options granted after 2019.  This article examines and comments on the proposed changes.Mon, 08 Jul 2019 00:00:00 Za80d3a38-07aa-402c-bf74-1d076fbe8e83https://gowlingwlg.com/en-ca/insights-resources/client-work/2019/gowling-wlg-advises-h-t-group-plc-on-share-placingGowling WLG is advising H&T Group plc on its proposed acquisition of 65 trading stores and a further 29 pledge books.Wed, 03 Jul 2019 00:00:00 Zf6581666-0da9-45a4-9b0f-fba5b869f8a1https://gowlingwlg.com/en-ca/insights-resources/client-work/2019/atlantic-street-capital-portfolio-company-gat-airOn June 28, 2019, Georgia-based GAT Airline Ground Support (“GAT”), a portfolio company of Atlantic Street Capital, acquired British Columbia-based Strategic Aviation Holdings Ltd. (“Strategic Aviation”). The merged businesses will continue to operate under their current brands and be identified as a GAT company.Fri, 28 Jun 2019 00:00:00 Z80b95df3-a47f-4a05-b1e1-a99a217a222bhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2019/canadian-hospital-specialties-acquires-ryan-medicaOn June 26, 2019, Canadian Hospital Specialties Limited ("CHS"), a portfolio company of private equity firm Cortec Group, acquired Ryan Medical Distributors Inc., a privately-owned Canadian distributor specializing in premium medical products for cardiac surgery and perfusion.Wed, 26 Jun 2019 00:00:00 Z5ccb608b-6211-4cf5-bcc6-0d7b21f0c1d3https://gowlingwlg.com/en-ca/insights-resources/client-work/2019/dawn-foods-completes-cross-border-acquisitionOn June 21, 2019, Dawn Food Products (Dawn Foods) acquired from Ardent Mills an ingredient mix facility in Burlington, Ontario and Ardent Mills' sweet goods business in Canada. Financial terms of the transaction were not disclosed.Fri, 21 Jun 2019 00:00:00 Z04752725-e593-4716-bc35-1b3dc52e2b37https://gowlingwlg.com/en-ca/insights-resources/articles/2019/pensions-tax-mistakes-can-sometimes-be-undoneHMRC has confirmed it is not appealing against the tribunal's ruling that a mistake could be treated as if it had not been made.Thu, 20 Jun 2019 13:16:00 Z9cbe5ceb-df1d-449e-851a-5da092f1bb03https://gowlingwlg.com/en-ca/insights-resources/client-work/2019/silversmith-capital-partners-leads-investmentOn May 16, 2019, PDFTron Systems announced that it had secured a US$71 million investment led by Silversmith Capital Partners.Thu, 16 May 2019 00:00:00 Z41b5eb35-0cfa-42c2-89a0-696931326325https://gowlingwlg.com/en-ca/insights-resources/articles/2019/limits-on-oral-interviews-confirmed-in-camecoMNR v Cameco Corporation, 2019 FCA 67 (Cameco) was an unsuccessful appeal by the Crown of a failed compliance order application in the Federal Court (FC).Tue, 07 May 2019 00:00:00 Zad8ffa2f-a671-4d1a-b87a-bbb30b38cf32https://gowlingwlg.com/en-ca/insights-resources/client-work/2019/newell-brands-divests-process-solutionsOn May 1, 2019, Newell Brands Inc. completed its divestiture of Process Solutions to an affiliate of One Rock Capital Partners, LLC.Wed, 01 May 2019 00:00:00 Z66323b55-f07f-4754-b3da-bd8645c53123https://gowlingwlg.com/en-ca/insights-resources/client-work/2019/cci-wireless-completes-acquisition-of-wibandEffective May 1, 2019, CCI Wireless is now Canada's second-largest wireless internet service provider.Wed, 01 May 2019 00:00:00 Z59e89b5b-dacf-49e5-8254-f713003c9345https://gowlingwlg.com/en-CA/insights-resources/client-work/2019/logan-resources-closes-subscription-receipt-offerOn April 30, 2019, Logan Resources Ltd. (TSXV: LGR) announced that it had completed a public offering of subscription receipts for gross proceeds of approximately $4 million. Haywood Securities Inc. acted as lead agent in respect of the offering.Tue, 30 Apr 2019 00:00:00 Z290f9632-c40b-439d-afff-abdfaa3bb235https://gowlingwlg.com/en-ca/insights-resources/client-work/2019/gridiron-capital-acquires-jacent-strategicOn April 25, 2019, Lariat Partners announced the sale of Jacent, North America's leading retail merchandising expert, to Gridiron Capital.Thu, 25 Apr 2019 00:00:00 Z6145b9d7-50a2-4194-a37d-201cd48d9722https://gowlingwlg.com/en-ca/insights-resources/client-work/2019/slr-consulting-acquires-novus-environmentalOn April 23, 2019, SLR Consulting, a global leader in environmental and advisory solutions, announced that it had acquired Novus Environmental Inc., a 25-person firm based in Guelph, Ontario.Tue, 23 Apr 2019 00:00:00 Z51595456-f1ab-4af4-8636-e26f3caaf73dhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2019/metalla-closes-12m-convertible-loan-facilityOn April 23, 2019, Metalla Royalty & Streaming Ltd. (TSXV: MTA) (OTCQX: MTAFF) (FRANKFURT: X9CP) announced that it had closed its convertible loan facility of $12 million with Beedie Capital to fund acquisitions of new royalties and streams.Tue, 23 Apr 2019 00:00:00 Z836ef78a-5c24-46ee-a0d8-a5c8f2411d94https://gowlingwlg.com/en-ca/insights-resources/client-work/2019/blackstone-completes-10-year-notes-offeringOn April 10, 2019, Blackstone (NYSE: BX) completed its previously announced offering of €600 million of 1.500% senior notes due 2029 of Blackstone Holdings Finance Co. L.L.C., its indirect subsidiary.Wed, 10 Apr 2019 00:00:00 Z1fdf2990-5947-47db-9217-f70d331dd7b0https://gowlingwlg.com/en-ca/insights-resources/articles/2019/permanent-establishment-risks-for-employeesMany businesses with cross border operations rely on their globally mobile employees to maintain relationships with their overseas customer bases.Mon, 08 Apr 2019 00:00:00 Za07f63db-c69c-4abf-9c6f-a5d8b14e6859https://gowlingwlg.com/en-ca/insights-resources/client-work/2019/nav-canada-completes-250-million-issuanceOn March 29, 2019, NAV CANADA announced that it had completed an issue of $250 million 31.5-year General Obligation Notes. Gowling WLG advised NAV CANADA with respect to this issuance.Fri, 29 Mar 2019 00:00:00 Zcc0bc398-e8c5-48b4-a67a-211af1b261cehttps://gowlingwlg.com/en-CA/insights-resources/client-work/2019/doxim-acquires-messagingdirectGowling WLG advises Doxim on the acquisition of MessagingDirect, Ltd.Thu, 28 Mar 2019 00:00:00 Z0c515792-fd89-4fb6-a210-ade4a21cd0e5https://gowlingwlg.com/en-ca/insights-resources/articles/2019/budget-2019-positioning-for-a-fall-electionWith Canada's top marginal tax rates described by some analysts as 'punitively high', and with the Canadian economy sliding to an annualized rate of growth of only 0.4 per cent in the fourth quarter, many were hoping for tax reductions in Budget 2019 that would help make Canada more competitive.Wed, 20 Mar 2019 00:00:00 Z176bdcb5-566d-4c78-a888-7fe03b4d71d8https://gowlingwlg.com/en-CA/insights-resources/client-work/2019/tecton-energy-services-acquired-by-klx-energy-serOn March 20, 2019, KLX Energy Services Holdings, Inc. (NASDAQ: KLXE) announced that it had acquired Tecton Energy Services.Wed, 20 Mar 2019 00:00:00 Z54c54d57-9e2e-40e1-8a8c-bbfaedf989d3https://gowlingwlg.com/en-CA/insights-resources/client-work/2019/pleatco-completes-acquisition-milton-manufacturingOn March 18, 2019, Align Capital Partners announced that its portfolio company Pleatco, LLC had acquired Milton Manufacturing Inc.Mon, 18 Mar 2019 00:00:00 Z5ae26511-1c84-4f08-83a9-0ce84d14f442https://gowlingwlg.com/en-ca/insights-resources/client-work/2019/balmoral-resources-closes-spring-placementsOn March 15 and April 11, 2019, Balmoral Resources Ltd. (TSX: BAR) closed the first and second tranches of its Spring 2019 non-brokered private placements of flow-through shares and non-flow-through units for aggregate gross proceeds of $2,131,503.90.Fri, 15 Mar 2019 00:00:00 Z1063859b-a035-492b-bde3-f4ac32367e5chttps://gowlingwlg.com/en-CA/insights-resources/client-work/2019/aleafia-health-emblem-complete-plan-of-arrangementOn March 14, 2019, Aleafia Health Inc. (TSXV: ALEF) (OTC: ALEAF) (FRA: ARAH) and Emblem Corp. (TSXV: EMC) (OTCQX: EMMBF) announced that they had completed the previously announced plan of arrangement under the provisions of the Canada Business Corporations Act in an all share transaction valued at approximately $172.3 million at the time of the deal's announcement.Thu, 14 Mar 2019 12:00:00 Zb8f9ecaa-ca0c-49f3-a396-f4120766a102https://gowlingwlg.com/en-ca/insights-resources/client-work/2019/namaste-technologies-completes-share-acquisitionCannabis e-commerce company Namaste Technologies Inc. in its acquisition of 49% of Pineapple Express Delivery Inc.Wed, 13 Mar 2019 00:00:00 Z6e308ec4-fb54-4496-932e-6398246d36a6https://gowlingwlg.com/en-ca/insights-resources/articles/2019/quebec-moves-to-tax-digital-goods-virtual-marketChanges to the rules related to the Québec Sales Tax (QST) may mean that your company is now required to collect the QST on sales even if you have no connection to Québec.Mon, 11 Mar 2019 00:00:00 Z82ad0dcd-2cf1-4110-9f1d-8e970be5acc6https://gowlingwlg.com/en-ca/insights-resources/client-work/2019/firm-capital-mortgage-investment-corp-23m-dealOn March 1, 2019, Firm Capital Mortgage Investment Corporation announced that it had closed its previously announced bought deal offering of common shares, which includes the exercise in full by the underwriters of their option to purchase additional shares, for gross proceeds of approximately $23m.Fri, 01 Mar 2019 00:00:00 Ze3b53270-828f-4e86-88e7-514c0b2b171chttps://gowlingwlg.com/en-CA/insights-resources/client-work/2019/mailchimp-completes-cross-border-acquisitionOn March 1, 2019, The Rocket Science Group (dba Mailchimp) acqui-hired the team behind Vancouver-based LemonStand eCommerce Inc.Fri, 01 Mar 2019 00:00:00 Z1d2d0d21-f549-4583-8c6f-93b9200e59a1https://gowlingwlg.com/en-CA/insights-resources/client-work/2019/cooper-equipment-rentals-acquires-prime-rentalsOn March 1, 2019, Cooper Equipment Rentals Limited ("Cooper") acquired the business of Prime Rentals Ltd. in southern Alberta.Fri, 01 Mar 2019 00:00:00 Z8ab53e19-dcac-40ac-9131-a46aaf436fc9https://gowlingwlg.com/en-CA/insights-resources/client-work/2019/gowling-wlg-advises-rigby-group-over-fluidone-saleInternational law firm Gowling WLG has advised Rigby Group on the sale of leading data connectivity platform FluidOne Limited to Livingbridge for an undisclosed sum.Thu, 28 Feb 2019 00:00:00 Z57b6dff5-5b5d-4931-b9d3-8a00cc6b9969https://gowlingwlg.com/en-CA/insights-resources/client-work/2019/general-catalyst-leads-series-a-venture-round-forOn February 27, 2019, Flashfood announced that it had raised an undisclosed venture round lead by General Catalyst. Gowling WLG advised General Catalyst in Canada with respect to this investment.Wed, 27 Feb 2019 00:00:00 Z9e0e55d7-f70f-4c98-8cd4-2fcc76b82284https://gowlingwlg.com/en-CA/insights-resources/client-work/2019/hi-c-completes-inaugural-offeringOn Feb. 22, 2019, HPC Housing Investment Corporation ("HI-C") closed a $33.1 million private placement of Senior Unsecured Series Notes, the proceeds of which will be advanced to provide long term financing for affordable housing projects in Canada. The Canada Life Assurance Company is the sole investor in the Notes.Fri, 22 Feb 2019 00:00:00 Z60214c55-f9b2-430e-b704-0ddbbd47ac2bhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2019/gowling-wlg-advises-a-f-blakemore-sonInternational Law firm Gowling WLG has advised A.F Blakemore & Son Ltd on its acquisition of the business of high street eatery chain Philpotts from the administrators of Philpotts Limited and Patisserie Valerie Group.Fri, 15 Feb 2019 00:00:00 Z64a61364-c5f7-4776-9b49-9631019a7c02https://gowlingwlg.com/en-CA/insights-resources/client-work/2019/mccall-macbain-foundation-single-largest-giftOn Feb. 13, 2019, John and Marcy McCall MacBain announced the McCall MacBain Scholarships at McGill University, created through a landmark donation of $200 million, the single-largest gift in Canadian history.Wed, 13 Feb 2019 00:00:00 Z315cb8e4-69f5-4515-810a-6c9b15b5a84chttps://gowlingwlg.com/en-CA/insights-resources/client-work/2019/tree-of-life-acquires-numageOn Feb. 8, 2019, Tree of Life Canada ULC acquired Numage Trading Inc., a Canadian importer and distributor of Italian specialty foods located in Concord, Ontario.Fri, 08 Feb 2019 00:00:00 Z51e62525-5370-40d0-b3d7-9471ef557952https://gowlingwlg.com/en-ca/insights-resources/client-work/2019/builders-supplies-limited-cross-border-acquisitionOn Feb. 7, 2019, US-based Foundation Building Materials, Inc. (NYSE: FBM) announced its cross-border acquisition of Builders' Supplies Limited of Mississauga, Ontario.Thu, 07 Feb 2019 00:00:00 Z6e38ea60-a911-4e35-82e4-ff6ebcb0d3aahttps://gowlingwlg.com/en-CA/insights-resources/client-work/2019/batteryone-acquires-royalty-on-dumont-nickel-cobalOn January 22, 2019 BatteryOne Royalty Corp. announced that it had acquired a 2.0% net smelter return royalty on future production over metals from the Dumont Nickel-Cobalt project.Tue, 22 Jan 2019 00:00:00 Ze60946c6-38f7-48a4-9fab-c39747342ebahttps://gowlingwlg.com/en-CA/insights-resources/client-work/2019/cooper-equipment-rentals-acquires-star-rentalsGowling WLG advised Cooper Equipment Rentals Limited on the acquisition and associated financing of Star Rentals Ltd. In British Columbia.Mon, 21 Jan 2019 12:00:00 Z672b471a-5fe9-486d-b080-e8cef17cb20ehttps://gowlingwlg.com/en-ca/insights-resources/client-work/2019/haco-group-completes-cross-border-acquisitionOn Jan. 15, 2019, HACO Group, an international manufacturer and distributor of food products based in Switzerland, acquired Altius Spices and Seasonings Inc. of Montréal, Quebec. The value of the acquisition was not disclosed.Tue, 15 Jan 2019 00:00:00 Z80183ae4-48c0-4140-a2e8-b03d4d68775ehttps://gowlingwlg.com/en-CA/insights-resources/client-work/2019/fertin-pharma-completes-crossborder-acquisitionOn Jan. 7, 2019, Fertin Pharma A/S announced that it had acquired Tab Labs Inc.Mon, 07 Jan 2019 00:00:00 Za1548113-a98b-4c26-8e24-4051fcb13522https://gowlingwlg.com/en-CA/insights-resources/client-work/2018/first-bauxite-corporation-completes-going-privateOn Dec. 21, 2018, First Bauxite Corporation ("First Bauxite") completed its previously announced going-private transaction via an arrangement under a statutory plan of arrangement pursuant to section 288 of the Business Corporations Act (British Columbia).Fri, 21 Dec 2018 00:00:00 Z9d8a8e7d-d0fb-428b-8fd3-0fc9434afba3https://gowlingwlg.com/en-CA/insights-resources/client-work/2018/echelon-wealth-partners-acquires-dundee-securitiesOn Dec. 14, 2018, Echelon Wealth Partners Inc. ("Echelon") announced that it had acquired Dundee Securities Ltd. from Dundee Global Investment Management Inc.Fri, 14 Dec 2018 00:00:00 Zb665c6bf-fee2-40f7-aa3a-990804745b4bhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2018/quandl-acquired-by-nasdaqOn Dec. 4, 2018, Nasdaq, Inc. (Nasdaq: NDAQ) announced that it had completed its cross-border acquisition of Quandl Inc., a leading provider of alternative and core financial data. Nasdaq plans to combine Quandl with its existing Analytics Hub business within Global Information Services.Tue, 04 Dec 2018 00:00:00 Zfedd0df3-ecdd-4697-8462-9136567ac426https://gowlingwlg.com/en-CA/insights-resources/client-work/2018/cannmart-acquires-buds2go-caOn Dec. 3, 2018, Namaste Technologies Inc. (TSXV: N) (FRANKFURT: M5BQ) (OTCMKTS: NXTTF) announced that its wholly-owned subsidiary, Cannmart Inc., had acquired the domain Buds2go.ca from 1181530 BC Ltd.Mon, 03 Dec 2018 00:00:00 Z21d4d572-bfd7-4f04-926f-4ded1666470fhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2018/firm-capital-mortgage-investment-corporation-closeOn November 23, 2018, Firm Capital Mortgage Investment Corporation announced it had closed its bought deal offering of $25m aggregate principal amount of 5.50% convertible unsecured subordinated debentures of the Corporation due January 31, 2026.Fri, 23 Nov 2018 00:00:00 Z44ff954d-8208-4d63-a9e2-1427ef577d27https://gowlingwlg.com/en-CA/insights-resources/client-work/2018/gowling-wlg-advises-client-brockwell-energyGowling WLG's Energy team advised in the dynamic subsidy-free renewable energy market, supporting client Brockwell Energy, Hargreaves Services' renewable energy division, upon its disposal.Tue, 06 Nov 2018 00:00:00 Zf34490b7-bd4e-49e7-a160-4a2ace997925https://gowlingwlg.com/en-CA/insights-resources/client-work/2018/riverside-acquires-surewerx-from-penfundOn November 2, 2018, The Riverside Company ("Riverside") acquired SureWerx from Penfund.Fri, 02 Nov 2018 11:00:00 Z09835cfe-2a30-43a8-a0b4-bab9473771c1https://gowlingwlg.com/en-CA/insights-resources/client-work/2018/gowling-wlg-advises-brockwell-energyEnergy experts from the international law firm, Gowling WLG, advised Brockwell Energy Limited on its spin-out by Hargreaves Services PLC for initial gross proceeds of £21 million.Tue, 23 Oct 2018 00:00:00 Zd8fad3db-4c64-47ab-b562-b665e2bf0003https://gowlingwlg.com/en-CA/insights-resources/client-work/2018/molson-coors-canada-and-hexo-launch-trussOn October 4, 2018, Molson Coors Canada and HEXO Corp. announced that they had closed the transaction announced on August 1, 2018, to form a joint venture.Thu, 04 Oct 2018 00:00:00 Z2d68822c-c790-4123-99ba-0741e33093d6https://gowlingwlg.com/en-CA/insights-resources/client-work/2018/epcor-acquires-collus-powerstreamOn Oct. 3, 2018, the Town of Collingwood announced that it had sold its electrical utility Collus Powerstream to EPCOR Utilities Inc., following the successful completion of two share purchase transactions.Wed, 03 Oct 2018 00:00:00 Zd6635343-a5a5-4979-afa5-ca0e1bff2114https://gowlingwlg.com/en-CA/insights-resources/client-work/2018/dubois-chemicals-acquires-ipac-chemicals-power-cOn October 1, 2018, Dubois Chemicals Canada Inc., a subsidiary of DuBois Chemicals, Inc., acquired Vancouver-based IPAC Chemicals & Power Chemicals, market leading providers of unique specialty chemicals for the mining and sulphur industries.Mon, 01 Oct 2018 00:00:00 Z39d53cfd-3a05-4a0f-a033-33f9068b7289https://gowlingwlg.com/en-CA/insights-resources/client-work/2018/vectorworks-acquires-resolve-software-solutionsOn Sept. 27, 2018, Vectorworks, Inc. announced that it had opened a new corporate office in Vancouver, British Columbia. To facilitate this new office, Vectorworks acquired Resolve Software Solutions and the assets of Paxar Technologies Corp., both long-time distributors of Vectorworks software.Thu, 27 Sep 2018 00:00:00 Zc12c46c3-e350-4332-8498-3f5aa417a08dhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2018/gowling-wlg-advises-oxbotica-funding-boostInternational law firm Gowling WLG have advised client Oxbotica on its £14 million investment to accelerate the autonomous vehicle company's international growth strategy.Wed, 26 Sep 2018 00:00:00 Z355cdffb-7c80-45fe-bc3f-d19990073f89https://gowlingwlg.com/en-CA/insights-resources/podcasts/2018/tax-update-and-penp-rules-2018There was a significant change to the tax treatment of payments in lieu of notice on 6 April 2018.Tue, 25 Sep 2018 00:00:00 Z9775d2c1-278f-45ac-8948-bb9e6e5348f8https://gowlingwlg.com/en-ca/insights-resources/articles/2018/cra-provides-relief-for-lossesTaxpayers victimized by fraudulent investment schemes (Fraudulent Investment Schemes) may find some relief by deducting their losses. Recent Canada Revenue Agency (CRA) administrative statements provide welcome guidance to taxpayers whose investments have been defrauded in a financial scam.Tue, 18 Sep 2018 00:00:00 Z12166d0d-263e-45a5-b524-3a890ea17548https://gowlingwlg.com/en-ca/insights-resources/articles/2018/federal-court-restricts-cra-fishing-expeditionsIn Canada (National Revenue) v. Hydro-Québec (2018 FC 62) (Hydro-Québec), the Federal Court (FC) restricted the Canada Revenue Agency’s (CRA) authority to force businesses to provide information about their customers pursuant to section 231.2 of the Income Tax Act (Act).Tue, 18 Sep 2018 00:00:00 Z2a3a4b54-ef7a-4a1a-8365-2364a20ffac0https://gowlingwlg.com/en-ca/insights-resources/articles/2018/anticipating-the-tax-implications-of-brexitWhile it is still too early to take a position on the actual consequences of Brexit, the main tax implications for groups with operations both in France and in the UK can and should already be anticipated.Wed, 05 Sep 2018 00:00:00 Z73c8de9c-9d27-4d1b-b708-049f63a2f54dhttps://gowlingwlg.com/en-ca/insights-resources/articles/2018/what-might-brexit-mean-for-international-disputesInternational supply arrangements give rise to the risk of cross-border disputes. What should British businesses consider when it comes to cross-border disputes?Wed, 05 Sep 2018 00:00:00 Za855250a-cc1a-40e8-a56c-18d48491600fhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2018/tree-of-life-canada-acquires-equity-stakesOn August 31, 2018, Tree of Life Canada ULC acquired a strategic equity stake in four Canadian firms.Fri, 31 Aug 2018 00:00:00 Zd64c56f6-aa62-45de-8b1d-1e3dcd7d0d33https://gowlingwlg.com/en-CA/insights-resources/client-work/2018/interrent-reit-closes-bought-deal-financingOn Aug. 9, 2018, InterRent Real Estate Investment Trust (TSX: IIP.UN) stated the closing of its previously announced public offering of 10,798,500 trust units from treasury, including the full exercise of the over-allotment option granted to the underwriters, for gross proceeds of $115,004,025.Thu, 09 Aug 2018 00:00:00 Z5f852217-be0e-468b-89d2-6f9ce77d7f5chttps://gowlingwlg.com/en-ca/insights-resources/articles/2018/canada-takes-next-steps-towards-implementing-mliOn May 28, 2018, Canada introduced Bill C‑82, which, if passed, will bring into force the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The Bill passed the first reading in the House of Commons on June 20.Wed, 08 Aug 2018 00:00:00 Z9c183bc6-dc89-4998-ad6b-845cbd3757bfhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2018/norwest-corporation-acquired-by-stantecOn August 8, 2018, global engineering and design firm Stantec announced its results for the second quarter ending June 30, 2018.Wed, 08 Aug 2018 00:00:00 Z7ddb38e6-13f4-4005-8666-906173da7458https://gowlingwlg.com/en-CA/insights-resources/client-work/2018/teranet-affiliate-completes-acquisitionOn Aug. 3, 2018, an affiliated entity of Teranet Inc., CM Solutions Inc., acquired all of the issued and outstanding shares of D+H Collateral Management Corporation, a division of Finastra Holdings Inc.Fri, 03 Aug 2018 00:00:00 Z92a36cac-f835-4848-8e54-381d77ece8a9https://gowlingwlg.com/en-CA/insights-resources/client-work/2018/cvc-fund-vi-acquires-the-alpha-corporationOn May 2, 2018 CVC Capital Partners announced that CVC Fund VI had signed a definitive agreement to acquire The Alpha Corporation. The transaction includes AOC, LLC, the primary asset and wholly-owned subsidiary of The Alpha Corporation.Wed, 01 Aug 2018 00:00:00 Z06d8e079-f17e-4b3f-9054-4e2bad633228https://gowlingwlg.com/en-CA/insights-resources/client-work/2018/scythian-biosciences-announces-193-million-saleOn July 17, 2018, Scythian Biosciences Corp. (TSXV: SCYB) (Frankfurt: 9SB) (OTC – Nasdaq Intl: SCCYF) announced that it had entered into a strategic deal with Aphria Inc. (TSX: APH) for Aphria to acquire Scythian's Latin American and Caribbean assets.Tue, 17 Jul 2018 00:00:00 Zb2e41f95-67b6-4422-b074-f0bf178ec3b1https://gowlingwlg.com/en-CA/insights-resources/client-work/2018/idexx-acquires-smart-flowOn July 17, 2018, IDEXX, a global leader in veterinary diagnostics and practice software, announced that it had acquired Smart Flow.Tue, 17 Jul 2018 00:00:00 Za5297dce-bd48-4e50-b2b9-ea9317d49916https://gowlingwlg.com/en-CA/insights-resources/client-work/2018/advising-meggitt-plc-on-its-new-supersiteGowling WLG has advised international aerospace, defence and energy engineering group Meggitt on the acquisition and development of its proposed new supersite in the West Midlands.Tue, 10 Jul 2018 00:00:00 Z1d6c61e5-2ae1-4204-ae9a-17488d8581b9https://gowlingwlg.com/en-CA/insights-resources/client-work/2018/urz-energy-and-azarga-uranium-complete-mergerOn July 5, 2018, URZ Energy Corp. and Azarga Uranium Corp. announced the completion of the previously announced merger between the two companies.Thu, 05 Jul 2018 00:00:00 Zccb409f1-6b9c-432e-aeb1-a9b9e482bc3ahttps://gowlingwlg.com/en-CA/insights-resources/client-work/2018/groupby-inc-announces-series-b-fundingOn June 19, 2018, GroupBy Inc. announced that it had closed its Series B financing from PeakSpan Capital.Tue, 19 Jun 2018 00:00:00 Z39ea74fc-5ab2-4248-ad72-8f31b81f2e67https://gowlingwlg.com/en-CA/insights-resources/client-work/2018/nouvelle-autoroute-30-closes-billion-refinancingOn June 14, 2018, ACS Group, through its Canadian subsidiary, ACS Infrastructure Canada, Inc. (Iridium), successfully closed the $1.218 billion (EUR 797 Million) offering of Senior Notes in a comprehensive refinancing of the project debt for its Autoroute 30 concession project.Thu, 14 Jun 2018 00:00:00 Zc3dc4f38-5c7a-4184-af0e-01e91c7668aahttps://gowlingwlg.com/en-CA/insights-resources/client-work/2018/largo-resources-completes-private-placementCounsel to Largo Resources Ltd. with respect to a private placement offering of US$150 million aggregate principal amount of senior secured notes.Tue, 22 May 2018 12:00:00 Z3f3b197a-14dd-4acf-98c4-eee3323b31a9https://gowlingwlg.com/en-CA/insights-resources/client-work/2018/gowling-wlg-advises-institutional-investorsGowling WLG acted as Canadian legal counsel on behalf of a syndicate of institutional investors in completing and the initial funding.Mon, 23 Apr 2018 00:00:00 Zf2e4255e-1bf4-46e3-861a-4ea2f4876d8ehttps://gowlingwlg.com/en-CA/insights-resources/client-work/2018/regal-ware-completes-cross-border-acquisitionOn April 16, 2018, Regal Ware, Inc. announced the acquisition of ESPRO®, a manufacturer of premium coffee and tea presses and accessories located in Vancouver, British Columbia. Gowling WLG advised Regal Ware in this transaction.Mon, 16 Apr 2018 00:00:00 Ze5330a8e-82f7-4cc6-89a2-10381e0db1cchttps://gowlingwlg.com/en-CA/insights-resources/client-work/2018/gowling-wlg-advises-minera-alamosOn April 13, 2018, Minera Alamos Inc. completed its acquisition of Corex Gold Corporation by way of a plan of arrangement. The value of the transaction is undisclosed.Fri, 13 Apr 2018 00:00:00 Z90cdbe0b-73a8-481b-90ba-5d6ed7ae041bhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2018/timber-automation-cross-border-acquisitionOn April 4, 2018, Timber Automation, LLC, a portfolio company of Blue Sage Capital, announced the acquisition of Québec-based VAB Solutions Inc. in a cross-border transaction.Wed, 04 Apr 2018 00:00:00 Zeb81d9ae-7b06-4238-af26-5d08dcc4c590https://gowlingwlg.com/en-CA/insights-resources/client-work/2018/entegrus-completes-merger-with-ascent-groupOn April 1, 2018, Entegrus Inc. completed its merger with the Ascent Group Inc. by way of an asset purchase, share purchase and subsequent amalgamation. The value of the transaction is undisclosed.Sun, 01 Apr 2018 00:00:00 Z012af201-7bdf-475d-bf60-d029cb5c7158https://gowlingwlg.com/en-CA/insights-resources/client-work/2018/energy-team-advises-innova-energy-on-uk-solar-farmGowling WLG's Energy team has advised Innova Energy on its acquisition of two UK-based solar farms.Mon, 26 Mar 2018 00:00:00 Z6f162ac1-5a3c-4867-8af6-05afa92982c5https://gowlingwlg.com/en-CA/insights-resources/client-work/2018/tetragenx-acquired-by-tropichem-research-labsOn March 21, 2018, Tropichem Research Labs, LLC acquired TetraGenx Inc.Wed, 21 Mar 2018 00:00:00 Zcee3e4c6-16cb-4a9d-a37c-2312e67dffebhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2018/gtt-communications-acquire-accelerated-connectionsOn March 12, 2018, GTT Communications, Inc. (NYSE: GTT) ("GTT") announced its cross-border acquisition of Toronto-headquartered Accelerated Connections ("ACI").Mon, 12 Mar 2018 23:00:00 Z69a9fead-1d66-4e44-a54f-aa54e1f8aea3https://gowlingwlg.com/en-CA/insights-resources/client-work/2018/accelerated-connections-acquired-by-gtt-communicatOn March 12, 2018, GTT Communications, Inc. (NYSE: GTT) announced its cross-border acquisition of Accelerated Connections Inc. ("ACI").Mon, 12 Mar 2018 11:00:00 Zc9958c19-b96f-4783-a851-c1e5b87dc735https://gowlingwlg.com/en-ca/insights-resources/articles/2018/budget-2018-sensible-measuresFrom a tax perspective, the headline news is that Budget 2018 completes the Government of Canada's general retreat from the astounding - and, to many in the tax community, largely incoherent - July Proposals to address passive investment income in private corporations.Wed, 28 Feb 2018 06:46:00 Zc57508a6-2be5-4672-b220-3f71d6ac3e30https://gowlingwlg.com/en-CA/insights-resources/client-work/2018/gowling-wlg-advises-cairngorm-capitalInternational law firm Gowling WLG has advised client Cairngorm Capital Partners LLP (Cairngorm Capital) on the acquisition of M J Wilson Group Limited (MJ Wilson), the leading independent UK distributor of process instrumentation and control products.Wed, 28 Feb 2018 00:00:00 Z32634eb5-c6d8-4e95-9470-6b3110858666https://gowlingwlg.com/en-CA/insights-resources/client-work/2018/namaste-technologies-closes-bought-dealOn February 27, 2018, Namaste Technologies Inc. announced that it had closed its previously announced bought deal short form prospectus offering of units.Tue, 27 Feb 2018 12:00:00 Z7ed45da4-4a87-4027-a7fc-af5495ad41d8https://gowlingwlg.com/en-CA/insights-resources/client-work/2018/gowling-wlg-advises-novacap-on-mailhot-acquisitionGowling WLG advised Novacap Industries IV, S.E.C., a leading Canadian private equity firm, on its acquisition of Mailhot Industries.Fri, 09 Feb 2018 00:00:00 Z620c6963-cff4-437e-881a-e0bd87f51a2dhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2018/battery-ventures-investment-in-curve-dentalOn February 8, 2018, Battery Ventures announced a significant equity investment in Curve Dental.Thu, 08 Feb 2018 12:00:00 Z02cb8b66-666f-4f25-92a6-8915d6f58863https://gowlingwlg.com/en-ca/insights-resources/articles/2018/bloomberg-tax-transfer-pricing-forumReproduced with permission from Transfer Pricing Forum, 07 TPTPFU 82. Copyright R 2017 by The Bureau of National Affairs, Inc. (800-372-1033) http://www.bna.com.Wed, 17 Jan 2018 00:00:00 Z48738849-2644-4f21-b6b6-8b633f854282https://gowlingwlg.com/en-ca/insights-resources/client-work/2017/gowling-wlg-advises-on-sale-of-majority-stake-in-fGowling WLG's Corporate, Finance and Tax team has advised the existing shareholders of long-standing client Forest Holidays on a further management buy-out.Thu, 21 Dec 2017 00:00:00 Ze29647fa-d850-4c56-8daa-6b73791dbb9ahttps://gowlingwlg.com/en-CA/insights-resources/client-work/2017/investment-funds-on-launch-of-listed-shipping-fundGowling WLG's top ranked investment funds team acted on the launch of Tufton Oceanic Assets Limited (Tufton Oceanic).Wed, 20 Dec 2017 00:00:00 Z218758a8-5d2e-4f89-9416-f9be5b5a3966https://gowlingwlg.com/en-ca/insights-resources/articles/2017/cra-finalizes-ic-for-income-tax-vdpOn December 15, 2017, the CRA released the final version of Information Circular IC 00-1R6 – Voluntary Disclosures Program (“VDP”) for income tax, after receiving and considering community input on the June 2017 draft version. This article summarizes the important differences between the draft and the final ICs and discusses implications and practical insights of the new VDP.Mon, 18 Dec 2017 00:00:00 Zeb3febe3-85e0-444b-a464-4036d0dc363ahttps://gowlingwlg.com/en-ca/insights-resources/articles/2017/ten-tax-compliance-tips-for-new-canadiansThe Canada Revenue Agency's recently announced 'postal code project' targets Canada's richest neighbourhoods, to identify non-compliance apparent from discrepancies between residents' tax reporting with their apparent wealth.Sun, 17 Dec 2017 00:00:00 Z4b9e94bd-bbf4-4b56-825d-e6a59d5fb17chttps://gowlingwlg.com/en-ca/insights-resources/client-work/2017/investment-funds-team-acts-on-new-european-logistiGowling WLG's top ranked investment funds team acted on the launch of Aberdeen Standard European Logistics Income PLC ("Aberdeen Standard Logistics").Thu, 14 Dec 2017 00:00:00 Z2da2e3fd-b98f-40ce-aa5f-886abe9ec35fhttps://gowlingwlg.com/en-ca/insights-resources/articles/2017/change-ahead-for-uk-commercial-property-tax-ratesOne of the attractions of the UK to non-UK resident investors in commercial property is a benign direct tax regime - in particular that capital gains can be realised free of UK tax. That is set to change from April 2019 under new proposed measures.Fri, 24 Nov 2017 00:00:00 Zed14e98b-ad50-43d3-a1c5-131823feac1ahttps://gowlingwlg.com/en-ca/insights-resources/articles/2017/proposed-foreign-merger-rollovers-rulesOn October 27, 2017, under Bill C-63, the Department of Finance released proposed amendments to the Income Tax Act (Canada) (“ITA”) introducing a new elective rule allowing non-residents tax-deferred rollover treatment on dispositions of certain taxable Canadian property (“TCP”) in a foreign merger.Wed, 15 Nov 2017 00:00:00 Z188b4493-3be6-4966-84ec-9f4b8615bee7https://gowlingwlg.com/en-ca/insights-resources/articles/2017/canadian-taxation-of-cryptocurrency-so-farCryptocurrency is digital 'money' that utilizes encryption techniques to regulate the issuance of units and verify their transfer.Tue, 14 Nov 2017 00:00:00 Z57747859-1052-41ee-90d7-2ae232948feahttps://gowlingwlg.com/en-ca/insights-resources/articles/2017/the-end-of-the-wealth-tax-and-the-creation-of-a-neThe draft of the French Finance Act 2018 is currently under discussion before the French Parliament. It should be voted on before the end of this year to come into force as of 1 January 2018.Tue, 24 Oct 2017 00:00:00 Zcf99ebdb-5f8a-4d05-8689-452b3d678708https://gowlingwlg.com/en-ca/insights-resources/articles/2017/five-pieces-of-tax-advice-for-start-upsTax is not always top-of-mind when launching your business; there are just so many other pieces to the puzzle to contend with. However, taking care of some basic tax matters at the beginning can help reduce your tax headache as your business takes flight.Fri, 20 Oct 2017 00:00:00 Zb7329652-49a4-45ae-bb40-c643072f5a95https://gowlingwlg.com/en-ca/insights-resources/articles/2017/digital-economy-taxationFollowing the informal council of finance ministers of the euro zone which was held on 16 September in Estonia, Paris, Berlin, Madrid and Rome are preparing a reform proposal aimed at fighting against the tax optimisation practices of GAFA and some actors of the digital economy in order to reduce or even circumvent their tax burden in Europe, even though they carry out a significant part of their activities and thus, potentially, their profits on this continent.Fri, 06 Oct 2017 06:05:00 Z117c0095-d687-498a-ae25-82bc19880e14https://gowlingwlg.com/en-ca/insights-resources/articles/2017/minister-s-audit-request-failed-to-meet-proportionSanity prevailed in a recent Federal Court (FC) decision involving an application by the Minister of National Revenue (Minister) to compel a taxpayer to produce approximately 25 employees for interviews as part of an audit.Tue, 19 Sep 2017 00:00:00 Z0b6b70af-72c2-499a-a844-7aef8447077bhttps://gowlingwlg.com/en-ca/insights-resources/articles/2017/minister-can-t-have-her-cake-and-eat-it-too-fedeOverturning a decision of the Federal Court (“FC”), the Federal Court of Appeal (“FCA”)[1] declared that the Minister of National Revenue (“Minister”) had to pay interest on $12.75 million collected from the taxpayer James T. Grenon.Tue, 19 Sep 2017 00:00:00 Z5f6288ba-3fc7-4706-94b4-729bc59ae505https://gowlingwlg.com/en-ca/insights-resources/articles/2017/new-taxpayer-relief-cra-information-circular-highlInformation Circulars inform taxpayers and practitioners on the Canada Revenue Agency's (CRA) interpretation and administration of the Income Tax Act (ITA).Tue, 19 Sep 2017 00:00:00 Z484bc96a-d0ea-457e-904d-1870ded6d3e6https://gowlingwlg.com/en-CA/insights-resources/client-work/2017/gowling-wlg-advises-vixs-systems-on-acquisition-byOn August 2, 2017, ViXS Systems Inc. was acquired by Pixelworks, Inc. in an all-stock transaction by way of a plan of arrangement under the Canada Business Corporations Act.Wed, 02 Aug 2017 23:00:00 Zc5d2ceab-ee5f-4109-a7a5-0e707dc5576dhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2018/imco-begins-to-manage-60-billion-of-assetsOn July 24, 2017, the Investment Management Corporation of Ontario (IMCO) began to manage the assets of its first two clients, the Workplace Safety Insurance Board (WSIB) and the Ontario Pension Board (OPB).Mon, 24 Jul 2017 00:00:00 Ze7f92c4b-7668-41dc-ac17-5b7bce30dd32https://gowlingwlg.com/en-CA/insights-resources/client-work/2017/gowling-wlg-advises-newell-brands-on-usd240-milliGowling WLG acted as Canadian counsel to Newell Brands Inc. on its USD$240-million sale of its winter sports business to Kohlberg & Company, L.L.C.Mon, 17 Jul 2017 00:00:00 Z70eee8c0-b068-4638-a7bc-de8550aff67ahttps://gowlingwlg.com/en-CA/insights-resources/podcasts/2017/the-taylor-review-on-the-gig-economy-good-workOur initial impressions on the Taylor Review from an employment and tax perspective.Thu, 13 Jul 2017 00:00:00 Ze48e8ad9-ff6c-459d-bf04-771580242799https://gowlingwlg.com/en-ca/insights-resources/articles/2017/incompatibility-of-the-french-3-taxThe CJEU confirmed on 17 May 2017 that the French 3% tax on distributed earnings is contrary to the Parent-Subsidiary Directive. French companies that received dividends from EU subsidiaries are thus authorized to claim repayment of the 3% tax levied in 2015 and 2016 on their dividend distributions. It also provides additional arguments to all the other French companies which had to pay this 3% tax.Fri, 07 Jul 2017 04:14:00 Z8a3d42d4-869e-4cea-9e42-e40bc97b368ahttps://gowlingwlg.com/en-ca/insights-resources/client-work/2017/gowling-wlg-advises-mariana-on-usd175-million-acqGowling WLG advised Mariana Resources Ltd. (Alternative Investment Market and the TSX Venture Exchange), a Guernsey incorporated exploration and development company with a diversified portfolio of precious metals projects in Latin America, Turkey and West Africa, on its USD$175-million acquisition by Sandstorm Gold Ltd. (Toronto Stock Exchange and NYSE), a gold royalty company, via scheme of arrangement.Mon, 03 Jul 2017 00:00:00 Z539aa6d4-5640-4fe1-bc4f-08ef00a6ecedhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2017/gowling-wlg-advises-gal-canada-on-golden-gate-capiGowling WLG acted as Canadian counsel to GAL Manufacturing Corp., GAL Canada Elevator Products Corp., Hollister-Whitney Elevator Corp. and affiliated entities (collectively, GAL) on an undisclosed majority equity investment by Golden Gate Capital.Mon, 26 Jun 2017 00:00:00 Zbc28fc62-b326-41ae-9c99-461f753496echttps://gowlingwlg.com/en-ca/insights-resources/client-work/2017/gowling-wlg-advises-exeter-on-cdn240-million-acquGowling WLG advised Exeter Resource Corporation, a Canadian mineral exploration company focused on the exploration and development of the Caspiche project in Chile, on its negotiated CDN$240-million acquisition, via a takeover bid, by Goldcorp Inc.Tue, 20 Jun 2017 00:00:00 Zbafa5286-8105-4ec4-98b3-28c8827b6476https://gowlingwlg.com/en-ca/insights-resources/articles/2017/2017-step-canada-cra-roundtableFollowing the presentation at the 2017 STEP Canada National Conference, we are pleased to provide you with a summary of the questions discussed at the Canada Revenue Agency ("CRA") Roundtable. Each question is followed by Gowling WLG's summary of the oral responses provided by the CRA. Although we believe our notes accurately summarize the CRA responses, we cannot guarantee that they do. Readers are advised to use the notes that follow with discretion and to refer to and rely on CRA’s official written responses when they become available.Thu, 15 Jun 2017 00:00:00 Z296de070-e3ba-4814-89d6-209e3c37d4cfhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2017/gowling-wlg-advises-deciem-on-the-estee-lauder-comGowling WLG advised DECIEM Beauty Group Inc., Toronto-based beauty products manufacturer, on an undisclosed equity investment by The Estée Lauder Companies Inc.Thu, 15 Jun 2017 00:00:00 Zd381b868-e628-43e5-99e3-df6dbee69a24https://gowlingwlg.com/en-ca/insights-resources/articles/2017/tea-maple-syrup-and-taxesCanada is one of the preferred locations for emigrating UK residents. Wealthy individuals will be persuaded by Canada’s unique mix of European and American culture, proximity to the American market, and consistent placement at the top of international happiness and standard-of-living indices.Tue, 13 Jun 2017 14:32:00 Z24ccea28-b632-48a2-9e7a-cb8407c031f0https://gowlingwlg.com/en-ca/insights-resources/articles/2017/canada-signs-the-multilateral-instrumentA representative of the Department of Finance expressed that it was Canada's goal to be ready to participate in the official signing ceremony.Tue, 13 Jun 2017 14:32:00 Z63ddf194-e9ad-492c-990d-6d493c54c9a6https://gowlingwlg.com/en-ca/insights-resources/articles/2017/when-the-cra-comes-knocking-ten-practical-guidelAll businesses should prepare for the possibility of a search warrant being executed at their premises by the police or a regulatory authority. One area in particular that ought to be a cause for concern for certain businesses is the increased likelihood of a search by the CRA.Tue, 06 Jun 2017 00:00:00 Z91a8eded-9505-4aa0-9acd-9874dcbd7618https://gowlingwlg.com/en-ca/insights-resources/articles/2017/unsuccessful-interest-relief-applicationRelief from interest accrual requested under the Income Tax Act (Canada) (“ITA”) in a complex and protracted dispute was recently rejected in Walsh v Canada, 2017 FC 411 (“Walsh”), a judicial review (“JR”) decision of the Federal Court (“FC”) issued in April 2017. The bases for the JR were that the CRA omitted to properly consider.Tue, 06 Jun 2017 00:00:00 Zd91c4bd5-227e-4a66-b8b5-6af2955f560chttps://gowlingwlg.com/en-ca/insights-resources/articles/2017/cra-enforcement-updateAs we reported in March, 2017, the Government of Canada is taking steps in response to the Finance Committee Report “The Canada Revenue Agency, Tax Avoidance and Tax Evasion: Recommended Actions." Earlier this month, the Minister of National Revenue (“Minister”) provided a progress update, including matters impacting tax dispute resolution.Tue, 06 Jun 2017 00:00:00 Zfbd15a0b-7c3a-4ac0-9363-de84c1bdc7b0https://gowlingwlg.com/en-ca/insights-resources/articles/2017/the-sifto-decision-is-the-minister-bound-by-mapOn March 10, 2017, the Tax Court of Canada (TCC) delivered its decision in Sifto Canada Corp. v. The Queen regarding the legal effect of a transfer pricing settlement reached under the Mutual Agreement Procedure Article (MAP Article) of the Canada - United States Tax Convention (Treaty).Tue, 16 May 2017 00:00:00 Z71ae43f6-d4e7-4412-becc-c1212ef73847https://gowlingwlg.com/en-ca/insights-resources/articles/2017/canada-s-adoption-of-the-multilateral-instrumentA representative of the Department of Finance confirmed that it's Canada's intention to adopt OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting.Tue, 16 May 2017 00:00:00 Zd19f48d5-b810-4320-a17c-2e1cd93b13d2https://gowlingwlg.com/en-ca/insights-resources/articles/2017/transfer-pricing-agreements-france-chapterWhile the arm's length principle is meant to be the guideline and reference of any intra-group contract, in order to spread as fairly as possible the income derived from a transaction, this may not always be the case in practice in a situation where parties are related and respective interest may not be divergent.Fri, 07 Apr 2017 00:00:00 Zf5b5d03d-9137-40bb-b36a-f417ba634dbchttps://gowlingwlg.com/en-ca/insights-resources/articles/2017/cra-s-audit-powers-restrictedOn March 30, 2017, the Federal Court of Appeal (“FCA”) rendered a taxpayer-friendly decision in BP Canada Energy Company (“BP”) with important implications for companies required by law to prepare audited financial statements. In brief, the FCA held that the CRA’s audit powers do not authorize general and unrestricted access to a corporation’s tax accrual working papers (“TAWPs”).Tue, 04 Apr 2017 00:00:00 Z89ebff28-1675-4e4f-97d1-d198bd93a180https://gowlingwlg.com/en-ca/insights-resources/articles/2017/budget-2017-no-game-changers-in-holding-pattern-bDespite rising deficits, Budget 2017 does not propose any general tax increases or other game-changing measures that were the subject of much speculation in recent weeks.Thu, 23 Mar 2017 00:00:00 Z159a4da9-ab5f-4ddd-b624-a2b95ef14e86https://gowlingwlg.com/en-ca/insights-resources/client-work/2017/gowling-wlg-advises-renntiger-resources-limited-onGowling WLG advised Renntiger Resources Limited on the acquisition of Renntiger by TSX Venture Exchange listed VR Resources Ltd., formerly Roll-Up Capital Corp, by way of plan of arrangement. The transaction constituted VR Resources qualifying transaction under TSXV policies.Tue, 21 Mar 2017 00:00:00 Zeacc93a3-7837-4bee-953b-b2b3eb72c893https://gowlingwlg.com/en-ca/insights-resources/articles/2017/french-tax-legislation-applicable-to-trustsUntil now, Article 1736 IV bis of the French Tax Code (FTC) has imposed very high penalties for trustees who fail to comply with filing requirements imposed by French tax legislation applicable to trusts.Mon, 20 Mar 2017 07:08:00 Z5cb11b49-e327-4428-a7a7-565aeaa16748https://gowlingwlg.com/en-CA/insights-resources/client-work/2017/gowling-wlg-advises-newell-brands-on-usd1-95-billOn March 10, 2017, Newell Brands Inc. completed the sale of its tools business to Stanley Black & Decker in a USD$1.95-billion transaction. The tools business includes brands Irwin, Lenox and Hilmor.Fri, 10 Mar 2017 00:00:00 Z06db2709-c3ac-431b-aea7-49cd1fe7f4c7https://gowlingwlg.com/en-ca/insights-resources/client-work/2017/gowling-wlg-advises-persta-resources-on-initial-puGowling WLG advised Persta Resources Inc. on its initial public offering and listing on the Main Board of the Hong Kong Stock ExchangeFri, 10 Mar 2017 00:00:00 Zb6816d77-df38-40ef-badd-a5bf6dd8adb0https://gowlingwlg.com/en-ca/insights-resources/articles/2017/tax-wars-its-time-to-think-strategically-on-interIn recent years tax laws have become extremely complex and tax authorities around the world have become much more aggressive. Being prepared to deal with an international tax audit and having a strategy to deal with tax authorities is a must.Tue, 07 Mar 2017 00:17:00 Zbce671e7-4e22-4e0a-ac3e-512fee3dc667https://gowlingwlg.com/en-ca/insights-resources/articles/2017/tax-avoidance-and-evasion-government-of-canada-repThe government of Canada’s recent report responding to the Finance Committee Report “The Canada Revenue Agency, Tax Avoidance and Tax Evasion: Recommended Actions” in turn recommended a number of actions affecting tax enforcement and dispute resolution.Tue, 07 Mar 2017 00:16:00 Zc5dedf53-5688-4a86-a442-ed755e26a48ehttps://gowlingwlg.com/en-ca/insights-resources/client-work/2017/gowling-wlg-advises-alectra-on-cdn607-million-hydOn February 28, 2017, Alectra Inc. completed its CDN$607-million acquisition of Hydro One Brampton from the Province of Ontario.Tue, 28 Feb 2017 00:00:00 Z75ff15fe-f0cd-4eb3-bc24-2096461ba17fhttps://gowlingwlg.com/en-ca/insights-resources/articles/2017/the-transfer-pricing-controversy-landscape-fraWhat are the main sources of transfer pricing controversy (transfer pricing audits and disputes) in your jurisdiction - e.g. characterisation, choice of method, choice of comparables, comparability adjustments, related party agreements and recharacterization, operation of the transfer pricing policies? Do auditors receive instruction to focus on these areas, or are they main sources of controversy because auditors focus on them by themselves?Fri, 17 Feb 2017 00:00:00 Z45ff637c-8758-4493-bfb0-16f6c15a4d94https://gowlingwlg.com/en-ca/insights-resources/articles/2017/the-3-tax-and-the-concept-of-beneficial-ownerUnder Article 990 D of the French tax code, companies and other entities (notably such as trusts and private foundations) which own French real estate, directly or indirectly, are subject to an annual 3% tax applied to the market value of the real estate.Wed, 08 Feb 2017 12:26:00 Z5afcda83-50bd-45fe-9d99-4e01839edf81https://gowlingwlg.com/en-ca/insights-resources/articles/2017/successful-quebec-shuffle-inter-provincial-tax-pThe British Columbia Court of Appeal recently released its judgment in Veracity Capital Corporation v. Canada (National Revenue), 2017 BCCA 3, holding that a tax planning structure commonly referred to as the Québec year-end shuffle did not constitute an avoidance transaction for purposes of the British Columbia general anti-avoidance rule (the BC GAAR). This is the first appellate level case addressing a provincial general anti-avoidance rule in Canada.Tue, 31 Jan 2017 00:00:00 Zf4d274ac-69c0-4e1b-b7f9-8cf172b758cfhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2017/enersource-horizon-utilities-and-powerstream-mergGowling WLG advised PowerStream Inc. and, separately, its shareholders (the Ontario cities of Vaughan, Markham and Barrie) with respect to the merger of Enersource, Horizon Utilities, and PowerStream, creating a new company known as Alectra Inc., and with respect to the subsequent acquisition of Hydro One Brampton by Alectra (expected to be completed in late February 2017).Tue, 31 Jan 2017 00:00:00 Z61f2e986-d3f1-42c3-ba16-a24a1e60ef8chttps://gowlingwlg.com/en-ca/insights-resources/articles/2017/no-changes-to-voluntary-disclosures-program-yetDespite wide speculation of significant changes, no substantive revisions were included in the Canada Revenue Agency’s (“CRA”) long-awaited updated information circular (“IC”) on its voluntary disclosures program (“VDP”). At a public presentation on December 1, 2015, CRA officials indicated that an amended and clarified VDP IC would be released in 2016, but no new IC was issued.Tue, 24 Jan 2017 00:00:00 Z9450ebdc-c397-4057-8aac-3fa414879bdahttps://gowlingwlg.com/en-ca/insights-resources/articles/2017/what-s-the-deal-with-privilegeThe Federal Court of Canada (“FC”) judgment in Minister of National Revenue v. Iggillis Holdings Inc. and Ian Gillis (2016 FC 1352) (“Iggillis”) is a recent and important decision concerning common interest privilege (“CIP”) – also known as deal/advisory or “allied lawyer” privilege.Tue, 24 Jan 2017 00:00:00 Zea5685d2-4d59-4bce-8f1a-dcaba7c2b1achttps://gowlingwlg.com/en-ca/insights-resources/client-work/2016/gowling-wlg-advises-ge-canada-on-bwxt-s-ge-hitachiOn December 16, 2016, BWXT Canada Ltd. completed its acquisition of all of the shares of the GE Hitachi Nuclear Energy Canada Inc. joint venture.Fri, 16 Dec 2016 00:00:00 Z860ed263-c3de-4224-a2b9-74ec9775fcf0https://gowlingwlg.com/en-ca/insights-resources/articles/2016/the-impact-of-the-autumn-statement-on-taxWe have had to look hard for the stand-outs on the taxing side. But there are a few.Wed, 23 Nov 2016 00:00:00 Z27a3f6b5-70fc-49f8-9bf5-a1ecd8ce1a50https://gowlingwlg.com/en-ca/insights-resources/articles/2016/autumn-statement-predictions-2016On Wednesday 23 November at 12:30, UK Chancellor Phillip Hammond will deliver his first Autumn Statement. Gowling WLG will be following the event live and tweeting reactions from our lawyers. In the meantime, a number of our lawyers have made predictions about what they would like to hear.Mon, 21 Nov 2016 07:03:00 Zec336f60-0d9d-4612-aee7-b636a50cda6fhttps://gowlingwlg.com/en-ca/insights-resources/articles/2016/how-to-choose-the-right-tax-structure-when-purchasMany wealthy individuals and families own a secondary home in France.Tue, 15 Nov 2016 05:07:00 Z0b198ca3-ca23-4f30-9277-95f60abf3645https://gowlingwlg.com/en-ca/insights-resources/articles/2016/awaiting-denouementWith one eye on an upcoming supreme court decision, tax residents of third-party states have the opportunity to claim a rebate on social contributions in France, Frederic Mege explains.Tue, 08 Nov 2016 00:00:00 Z212981c2-ff1f-4748-9b62-f938faef842dhttps://gowlingwlg.com/en-ca/insights-resources/articles/2016/aboriginal-taxation-reasonableness-of-bonusesBell v. The Queen 2016 TCC 175 is a Tax Court of Canada decision regarding whether employment bonuses paid to a status Indian by a corporation situated on a reserve were exempt from tax.Tue, 01 Nov 2016 01:00:00 Z710bed3b-0338-4d3c-b7fe-7e0ac083a04ahttps://gowlingwlg.com/en-ca/insights-resources/articles/2016/subsequent-legislative-changes-not-a-basis-for-finIn Oxford Properties Group Inc. v. The Queen, a case involving the application of the general anti-avoidance rule (GAAR), the Tax Court undertook a helpful review of the relevance of subsequent legislation in carrying out the abuse analysis under subsection 245(4) of the Income Tax Act (Canada) (ITA).Tue, 01 Nov 2016 00:00:00 Z43f010d7-865b-4d07-98ef-9f4626a8e984https://gowlingwlg.com/en-ca/insights-resources/articles/2016/federal-and-ontario-reassessment-periods-and-waive<p><span style="font-weight: normal"><em>Aubrey Dan Family Trust v. Minister of Finance, </em>2016 ONSC 3801 (&ldquo;<strong><em>ADFT</em></strong>&rdquo;) was a summary judgment motion in an appeal against an Ontario <em>Income Tax Act</em> (&ldquo;<strong>Ontario Act</strong>&rdquo;) assessment against the Aubrey Dan Family Trust (&ldquo;<strong>ADFT</strong>&rdquo;), issued in February 2012 for the 2007 taxation year.</span></p>Wed, 26 Oct 2016 05:00:00 Z5c87b61e-eb57-400f-89f2-8e6c9f25022bhttps://gowlingwlg.com/en-ca/insights-resources/articles/2016/interest-payable-on-gaar-assessmentQuinco Financial Inc. v. The Queen, 2016 TCC 190, is a Tax Court of Canada decision concerning a Rule 58 question of mixed fact and law related to an assessment of tax and interest payable under the general anti-avoidance provision.Wed, 26 Oct 2016 05:00:00 Zecdc79a6-d278-49da-8590-6425586cd5edhttps://gowlingwlg.com/en-ca/insights-resources/articles/2016/maintaining-privilege-for-cross-disciplinary-tax-aRedhead Equipment Ltd et al v. AG (Canada) (2016 SKCA 115) (“Redhead”) provides a helpful summary of key principles governing solicitor-client privilege when lawyers and accountants are involved in transactional work and tax planning.Wed, 26 Oct 2016 05:00:00 Z024e7ceb-9afd-4257-b89c-404b37933c32https://gowlingwlg.com/en-CA/insights-resources/client-work/2016/gowling-wlg-advises-the-crown-estate-on-purchase-oIn December 2015, Gowling WLG completed the transaction that saw client The Crown Estate and its partner Gingko Tree Investment Limited - together Fosse Park West LLP - acquire the 12.5 acre Castles Acre site in Leicester from Everards Brewery.Fri, 23 Sep 2016 00:00:00 Zc4ed070c-f993-4c37-9f22-21297332c013https://gowlingwlg.com/en-ca/insights-resources/client-work/2016/gowling-wlg-s-real-estate-experts-advise-telerealIn September 2015, Gowling WLG's real estate partner, Ed Colreavy, led a team of specialists in advising client Telereal Trillium on its acquisition of Lands Improvement Group (LIG) from BlackRock Europe Property Fund III.Fri, 23 Sep 2016 00:00:00 Z43752122-9b28-45d8-afeb-82c4e6f3bfa1https://gowlingwlg.com/en-ca/insights-resources/client-work/2016/gowling-wlg-provides-canadian-transactional-supporSeptember 23, 2016, Xiwang Foodstuffs Company Ltd. announced that it had completed its acquisition of Iovate Health Sciences International, Inc. via its acquisition of Iovate’s parent company, Kerr Investment Holding Corporation, from The Toronto Oak Trust for a total consideration of CDN$730m.Fri, 23 Sep 2016 00:00:00 Z0c4baf01-22ba-4f99-a5b6-738ecbad8088https://gowlingwlg.com/en-ca/insights-resources/articles/2016/french-tax-authorities-reduce-trustee-penaltiesUntil now, Article 1736 IV bis of the French Tax Code (FTC) has imposed very high penalties for trustees who fail to comply with filing requirements imposed by French tax legislation applicable to trusts.Wed, 21 Sep 2016 00:00:00 Z7b826bba-ddbf-4db6-a3b5-040a7fbda384https://gowlingwlg.com/en-CA/insights-resources/client-work/2016/gowling-wlg-advises-ovivo-on-180-million-acquisitGowling WLG advises Ovivo Inc. on $180-million acquisition by SKion Water International GmbH in partnership with Caisse de dépôt et placement du Québec.Fri, 16 Sep 2016 00:00:00 Zfb32ca00-0c67-440a-922b-9c334b3cf780https://gowlingwlg.com/en-ca/insights-resources/articles/2016/french-tax-legislation-applicable-to-trusts-positArticle 1736 IV bis of the French Tax Code (FTC) imposes very high penalties for trustees who fail to comply with filing requirements imposed by French tax legislation applicable to trusts. Similar penalties exist for French tax residents who fail to disclose their foreign bank accounts, albeit at lower rates - the fine is 5% if the funds exceed €50,000. In a decision dated 22 July 2016, the Constitutional Court ("Conseil Constitutionnel") has cancelled the 5% penalty in relation to failure to disclose foreign bank accounts.Thu, 15 Sep 2016 00:00:00 Z8aab2915-dea0-4c77-a14d-df098e97e877https://gowlingwlg.com/en-ca/insights-resources/articles/2016/clients-tax-and-cautionWith revamped enforcement powers and the international exchange of information, the CRA is ramping up to pursue impugned tax-motivated investments.Thu, 15 Sep 2016 00:00:00 Z1aea46bd-66e4-4159-8fc4-6575be0d835bhttps://gowlingwlg.com/en-ca/insights-resources/articles/2016/avoidance-of-the-business-limit-and-taxable-capitaTue, 13 Sep 2016 00:00:00 Z0aea4efe-7b65-4da5-88ce-2a586436c9b4https://gowlingwlg.com/en-ca/insights-resources/articles/2016/new-limits-on-the-small-business-deductionThis is article is part of a series dealing with draft legislation released for comment by the Department of Finance on July 29th. Read the complete series:Tue, 13 Sep 2016 00:00:00 Z0ef89859-53b7-40b8-ac0b-87ccfb68256dhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2016/gowling-wlg-advises-specialty-polymer-coatings-onOn September 8, 2016, Specialty Polymer Coatings, Inc. (SPC) closed on its acquisition by RPM International Inc. (RPM). SPC will operate as a free-standing business within the RPM Performance Coatings Group and report through the Carboline Company. The value of the transaction is undisclosed.Thu, 08 Sep 2016 00:00:00 Z2a7eb7f3-6895-43d6-9597-de8fc8028704https://gowlingwlg.com/en-ca/insights-resources/client-work/2016/gowling-wlg-advises-mundomedia-ltd-on-company-buyOn September 2, 2016, MUNDOmedia Ltd. announced that its CEO and Founder, Jason Theofilos, led a company buyout of 100% of the outstanding equity of the company along with private equity investors.Fri, 02 Sep 2016 00:00:00 Z0f879f72-57a4-4684-a7b6-760a9e39a6e6https://gowlingwlg.com/en-ca/insights-resources/articles/2016/french-social-contributionsSince 2012, social contributions have applied at a rate of 15.5% on French rental income earned as of 1 January 2012.Thu, 01 Sep 2016 00:00:00 Zb84ca820-cc64-47ab-bbba-1fdd1a54c53ahttps://gowlingwlg.com/en-CA/insights-resources/client-work/2016/gowling-wlg-advises-phoenix-contact-on-acquisitionGowling WLG advises Phoenix Contact GmbH & Co. KG on its acquisition of Perle Systems Limited, its first Canadian acquisition.Wed, 31 Aug 2016 00:00:00 Z57eb4757-e52c-4e67-906c-7acd5de8ead9https://gowlingwlg.com/en-ca/insights-resources/articles/2016/foreign-exchange-gains-on-debt-parkingTue, 30 Aug 2016 09:17:00 Ze7666d90-cd9f-473b-bdf3-5440db824928https://gowlingwlg.com/en-ca/insights-resources/articles/2016/cross-border-surplus-strippingBudget 2016 declared that the new Liberal government would ‘protect the integrity of Canada’s international tax system’ by introducing new tax measures to prevent unintended, tax-free cross-border distributions of capital to non-residents by narrowing the application of an existing exception to the cross-border anti-surplus-stripping rule.Tue, 30 Aug 2016 00:00:00 Z8ff6a49f-0aad-4894-9fd7-0db60bf015c7https://gowlingwlg.com/en-ca/insights-resources/articles/2016/new-penalty-to-support-the-common-reporting-standaCanada is now implementing a new international standard for the automatic exchange of financial account information between tax administrations referred to as the common reporting standard (“CRS”). Implementation of the CRS in Canada will result in Canadian financial institutions reporting to the CRA regarding financial accounts they maintain for non-residents and certain other reportable persons. It is proposed that the new CRS requirements take effect starting on July 1, 2017.Tue, 30 Aug 2016 00:00:00 Z85c45fa4-c2cd-48bb-8b38-5e6e986dd0e4https://gowlingwlg.com/en-ca/insights-resources/client-work/2016/gowling-wlg-advises-flinders-resources-and-tasmanOn August 25, 2016, Flinders Resources Limited and Tasman Metals Ltd. announced the closing of their plan of arrangement.Thu, 25 Aug 2016 15:32:00 Z62937b77-71af-4355-88c5-9e317f8748e5https://gowlingwlg.com/en-ca/insights-resources/articles/2016/changes-to-country-by-country-reportingBusinesses with international operations need to be aware of changes to the required transfer pricing documentation that will apply in the near future.Tue, 23 Aug 2016 16:00:00 Z9023c6d5-c11a-4218-abc8-3d82ae6a18a4https://gowlingwlg.com/en-ca/insights-resources/articles/2016/proposed-replacement-of-eligible-capital-propertyThis is article is part of a series dealing with draft legislation released for comment by the Department of Finance on July 29th.Tue, 23 Aug 2016 15:58:00 Z65e4ad34-9dcd-4912-ac41-dec6bfd024dehttps://gowlingwlg.com/en-ca/insights-resources/articles/2016/alternative-arguments-in-support-of-tax-assessmentThe Minister may not reassess after the normal reassessment period unless the taxpayer has filed a waiver, or the taxpayer's return included a misrepresentation attributable to carelessness, negligence or wilful default, or fraud was committed in filing the return.Tue, 23 Aug 2016 15:57:00 Z2e69e81b-b968-4d04-a85f-78591cf6336chttps://gowlingwlg.com/en-CA/insights-resources/client-work/2016/gowling-wlg-advises-manitok-energy-on-raimount-eneGowling WLG advises Manitok Energy Inc. on its $7-million acquisition of Raimount Energy Inc.Fri, 19 Aug 2016 00:00:00 Z105533f1-4b08-4810-a7a4-0b0e7c3f279dhttps://gowlingwlg.com/en-ca/insights-resources/articles/2016/sales-of-linked-notesIn Budget 2016, the Department of Finance continued its quest to eliminate investment products that have ‘character conversion’ features.Tue, 16 Aug 2016 01:50:00 Za94d6693-d0be-48c6-8fdd-3b69286bb9c3https://gowlingwlg.com/en-ca/insights-resources/articles/2016/the-evolving-taxation-of-derivativesCertain derivatives held on income account have been treated as inventory for tax purposes, thereby allowing the deduction of unrealized losses on such derivatives. This treatment was supported by the 2015 decision of the Tax Court of Canada in Kruger Inc. v. The Queen (2015 TCC 119), holding that certain foreign exchange related derivative contracts owned by the taxpayer at its year-end were inventory, and that the taxpayer was permitted (likely required) to value such derivatives at the lower of cost or FMV pursuant to section 10 of the ITA.Tue, 16 Aug 2016 01:50:00 Z9e9881af-67e4-4e1f-9722-491905fe9da5https://gowlingwlg.com/en-ca/insights-resources/articles/2016/taxation-of-switch-fund-sharesGeneral provisions in the ITA applicable to corporations and their shareholders provide that, in certain circumstances, an exchange of shares of a corporation by a taxpayer is deemed not to be a disposition or is deemed to be a disposition that occurs at the taxpayer’s adjusted cost base of its original shares.Tue, 16 Aug 2016 01:00:00 Z86c3d5ea-2bd7-46e0-a5b2-8816dfeeb986https://gowlingwlg.com/en-ca/insights-resources/articles/2016/foreigners-to-pay-new-b-c-property-transfer-taxDuring the past several years, public concern has increased in the Greater Vancouver Regional District (the GVRD) over the steep rise in home prices.Thu, 28 Jul 2016 17:06:00 Z74fb897d-4956-44c0-8dc5-dc3f24d0a1e5https://gowlingwlg.com/en-ca/insights-resources/articles/2016/brexit-impact-on-financial-services-institutionsOf all the many issues to be considered by the sector post-referendum, the issue that will certainly be near the front of the queue for negotiation is the matter of "passporting" financial services within the EU.Fri, 22 Jul 2016 00:00:00 Zf3ece830-09e2-4def-a3d3-a11506ff701ahttps://gowlingwlg.com/en-CA/insights-resources/client-work/2016/gowling-wlg-advises-h-d-advanced-manufacturing-comOn July 20, 2016, H-D Advanced Manufacturing Company, backed by The Riverside Company and Hicks Equity Partners, acquired Numeric Machine Company.Wed, 20 Jul 2016 00:00:00 Za58edb87-b5a9-41a7-a8c5-d344d428a712https://gowlingwlg.com/en-ca/insights-resources/articles/2016/fca-issues-guidance-on-the-suspension-of-fund-redeFollowing on from Britain's decision to leave the EU, and the week in which at least nine of the largest fund managers temporarily halted redemptions from their flagship open-ended property funds due to the exceptional level of redemption requests, the Financial Conduct Authority (FCA) issued guidance on fund suspensions on 8 July 2016.Wed, 13 Jul 2016 00:00:00 Z75f9c0a0-f25a-4eea-bc57-fd741bb89c0bhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2016/gowling-wlg-advises-fengate-capital-on-its-acquisiGowling WLG advises Fengate Capital Management Ltd. on its acquisition of Carillion Canada’s equity interest in Oakville Trafalgar Memorial Hospital.Tue, 12 Jul 2016 00:00:00 Zeb99501c-f0fe-49fa-bb98-e81e924de288https://gowlingwlg.com/en-ca/insights-resources/articles/2016/the-french-trust-registry-is-now-onlineOn 5 November 2013, the French Parliament voted in favour of a new Act introducing a trust registry to fight against tax evasion. This new Act needed a decree to be implemented. The decree was issued on 10 May 2016 and the registry is now available online as of 5 July 2016.Fri, 08 Jul 2016 04:51:00 Zddc17fce-1a77-4d2d-801c-a29687671027https://gowlingwlg.com/en-ca/insights-resources/articles/2016/brexit-a-leap-into-the-unknown-considerationsOn 23 June 2016, the UK voted to leave the European Union (EU) by a majority of 51.9% to 48.1% (of the 72.2% turnout of eligible voters). In fact, Scotland and Northern Ireland voted to remain in the EU, with 62% and 55.7% respectively of voters in favour of staying, but England and Wales took the opposite view.Fri, 01 Jul 2016 06:07:00 Z6d5fd1e8-df0f-409d-a9fa-712622598088https://gowlingwlg.com/en-ca/insights-resources/client-work/2016/gowling-wlg-advises-balmoral-resources-ltd-on-7On June 30, 2016, Balmoral Resources Ltd. closed its ‘flow-through’ private placement, including the full exercise of the over-allotment option.Thu, 30 Jun 2016 00:00:00 Zf563ea80-5d7c-487d-be60-df284cee98bahttps://gowlingwlg.com/en-CA/insights-resources/on-demand-webinars/2016/international-tax-crackdown-what-you-need-to-knowWith the Canada Revenue Agency cracking down on unreported international investments, taxpayers need to understand the risks they now face — and learn how to effectively manage the new challenges of the global tax landscape.Tue, 21 Jun 2016 10:54:00 Z0afdd00e-55bf-46cf-837c-915677d68f86https://gowlingwlg.com/en-ca/insights-resources/articles/2016/ip-migration-strategies-pre-and-post-bepsThe largest initiative in the transfer pricing world will change how the global operations of corporates are structured and international transactions are reported.Tue, 14 Jun 2016 00:00:00 Z1afb9310-c5ff-4be8-90c2-d2036c269ae4https://gowlingwlg.com/en-ca/insights-resources/articles/2016/the-federal-court-of-appeal-clarifies-the-de-factoControl is a concept that is relevant for a number of income tax rules. There are two types of control: de jure and de facto control. Determining de jure control is straightforward as it exists where a person (or group) has the power to elect a majority of the board of directors. De facto control is less concrete, requiring a determination of whether a person (or group) has direct or indirect influence that, if exercised, would result in factual control.Tue, 14 Jun 2016 00:00:00 Z68981dc6-9061-4ca1-a14d-67885b9d2f40https://gowlingwlg.com/en-ca/insights-resources/articles/2016/update-on-the-administrative-policy-for-a-stay-onAs of February 2016, under a new measure announced in the Action Plan in Response to the 2014-2015 Ombudsman Annual Report, Revenu Québec (“RQ”) has the administrative discretion to stay collection actions when an objection or an appeal is brought to a Québec Sales Tax (“QST”) assessment.Mon, 13 Jun 2016 00:00:00 Z5dd4a9cb-c085-453e-a0eb-a5c72084f3c7https://gowlingwlg.com/en-ca/insights-resources/articles/2016/supreme-court-of-canada-upholds-solicitor-client-pThe Supreme Court released two unanimous decisions on June 3, 2016 upholding solicitor-client privilege in the context of requirements (Requirements) by the Canada Revenue Agency (CRA) to produce documents or information for tax administration or enforcement purposes.Mon, 06 Jun 2016 00:00:00 Z50b45611-ad6d-44bc-adb9-1ca847f63936https://gowlingwlg.com/en-ca/insights-resources/articles/2016/panama-papers-the-canadian-government-s-developinThu, 02 Jun 2016 00:00:00 Z1d717c24-5d2e-45bf-a11b-8b3f7932b2a2https://gowlingwlg.com/en-ca/insights-resources/articles/2016/dissolved-corporation-lacks-standing-in-tax-courtIn 1455257 Ontario Inc. (2016 FCA 100), the Federal Court of Appeal (FCA) overruled its prior precedent and held that a dissolved corporation lacked capacity to initiate a Tax Court of Canada (TCC) appeal.Tue, 31 May 2016 00:00:00 Z426dfbdc-f71f-46fe-a9ff-7ff7ed1ef2b9https://gowlingwlg.com/en-ca/insights-resources/client-work/2016/gowling-wlg-advises-yangarra-resources-on-11-5-miMay 25, 2016, Yangarra Resources Ltd. completed its bought deal public offering by way of a short form prospectus for the sale of 10,000,000 common shares.Wed, 25 May 2016 00:00:00 Zc482e3ce-344e-4341-bb3a-4f271eaeca8bhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2016/gowling-wlg-advises-lenders-to-icon-infrastructureOn April 29, 2016, iCON Infrastructure Partners III, L.P., a fund advised by London, U.K.-based iCON Infrastructure LLP, completed a statutory plan of arrangement involving Capstone Infrastructure Corporation, a Toronto Stock Exchange-listed infrastructure company owning a diversified portfolio of assets.Fri, 29 Apr 2016 00:00:00 Z07314775-1ce5-40dd-84db-009aa99fd246https://gowlingwlg.com/en-ca/insights-resources/articles/2016/regulation-102-withholding-the-new-exemptionNon-resident employers often send employees to Canada to provide services to Canadian clients, to assist a Canadian affiliate, or to attend conferences. Top of mind at these times are immigration issues. However, given that the employees remain on the payroll of the non-resident employer, what is often overlooked are the Canadian income tax withholding and reporting obligations of the employer with respect to the consideration it pays the employees during this time.Tue, 26 Apr 2016 00:00:00 Ze3716eda-9539-48c0-8856-fe5500afa48dhttps://gowlingwlg.com/en-ca/insights-resources/articles/2016/will-the-cra-change-its-enforcement-in-wake-of-panThe “Panama Papers” – the unprecedented leak of 11.5 million confidential documents exposing more than 200,000 offshore entities, including several hundred established by Canadians – raises questions about how the Canada Revenue Agency should seek to enforce our tax rules against Canadians with offshore investments. While offshore holding companies can be perfectly legal and serve any number of legitimate purposes, they can also be used to hide income and avoid legitimate tax obligations. The line between legal avoidance and illegal evasion can blur.Thu, 07 Apr 2016 00:00:00 Ze47cf013-b37b-434b-982f-add181749ab7https://gowlingwlg.com/en-ca/insights-resources/articles/2016/contempt-of-court-facing-the-musicWed, 30 Mar 2016 00:00:00 Zc543f70f-3ae4-4d96-9a65-aa1a2b3a4adchttps://gowlingwlg.com/en-ca/insights-resources/articles/2016/revenu-quebec-promises-to-change-the-action-planRevenu Québec announced its action plan to respond to the highly critical Protecteur du citoyen 2014-2015 Annual Report (“Report”).Wed, 30 Mar 2016 00:00:00 Z473d5c1d-afb4-41fa-a45a-1ee0822ced78https://gowlingwlg.com/en-ca/insights-resources/articles/2016/technology-commercialization-forecast-heavy-clouThe Conference Board of Canada regularly publishes a 'Report Card on How Canada Performs' in a number of sectors including, the economy, environment, innovation and health among others.Mon, 28 Mar 2016 00:00:00 Z5fb0dd7d-e261-4f8e-9a6c-1705ad388803https://gowlingwlg.com/en-CA/insights-resources/client-work/2016/ontario-electrical-utility-companies-merge-to-creaGowling WLG is acting as counsel to PowerStream Inc. and, separately, its shareholders (the Ontario cities of Vaughan, Markham and Barrie) with respect to the $607-million purchase of Hydro One Brampton Networks Inc. by PowerStream, Enersource Corporation and Horizon Utilities Corporation.Thu, 24 Mar 2016 00:00:00 Za286234b-a6e3-4b2e-8f10-ef14d40b96d3https://gowlingwlg.com/en-ca/insights-resources/articles/2016/federal-budget-2016-incremental-not-fundamentalOn March 22, 2016 the Minister of Finance tabled Budget 2016, the first budget of the current government's mandate.Wed, 23 Mar 2016 00:00:00 Z9dfdd1f5-10b8-4f07-bf76-aeb5d55c0d3ahttps://gowlingwlg.com/en-ca/insights-resources/articles/2016/canada-s-new-tax-treaty-with-taiwan-10-key-aspectThe purpose of this article is to provide a brief summary of the main provisions of the Treaty that will be of interest to those residents in Canada or Taiwan who have, or are contemplating, personal or economic activity in the other territory.Tue, 15 Mar 2016 00:00:00 Zd760b807-f83c-4c15-a112-b1e1a06e1f94https://gowlingwlg.com/en-ca/insights-resources/client-work/2016/gowling-wlg-advises-mercia-technologies-plc-on-acqInternational law firm Gowling WLG has advised AIM-quoted Mercia Technologies PLC (Mercia) on its £11 million acquisition of Enterprise Ventures Group Ltd (Enterprise Ventures).Mon, 14 Mar 2016 04:00:00 Z1f53da6d-66cf-4328-8dc9-1a4ca37af1b2https://gowlingwlg.com/en-ca/insights-resources/client-work/2016/gowling-wlg-advises-empiric-student-property-on-40The Real Estate Finance and Investment Funds teams at Gowling WLG has advised longstanding client Empiric Student Property plc (Empiric) on a £40 million loan facility.Tue, 08 Mar 2016 05:00:00 Z2b9d532b-3cb5-47cb-b3c4-989b4c4212cchttps://gowlingwlg.com/en-ca/insights-resources/articles/2016/the-franco-filesFrench tax legislation applicable to trusts came into force on 31 July 2011. A decree regarding trustees' filing requirements was issued on 14 September 2012 and, on 16 October 2012, the French tax authorities issued their tax guidelines.Tue, 01 Mar 2016 00:00:00 Zb0be2b5d-d817-496a-8412-745c969e6850https://gowlingwlg.com/en-ca/insights-resources/client-work/2016/gfl-acquires-enviro-viridis-development-corporatioGowling WLG acted as counsel to Enviro-Viridis Development Corporation Inc. and the sellers, including NOVACAP, with respect to the purchase of Enviro-Viridis by GFL Environmental Inc. through its wholly-owned subsidiary, Services Matrec Inc.Tue, 01 Mar 2016 00:00:00 Ze5ae4c02-443f-42ba-9e4c-e2c74e94b429https://gowlingwlg.com/en-ca/insights-resources/articles/2016/sticks-and-stones-the-taxing-question-of-injury-tA payment for injury to feelings that is paid in connection with termination of employment is taxable. This is contrary to the established view of the Employment Appeal Tribunal (EAT). Our tax and employment specialists look at the current state of play in this evolving and often contradictory area of law.Thu, 11 Feb 2016 00:00:00 Z6a43d41f-abcb-4347-b44a-eee3a9415f89https://gowlingwlg.com/en-ca/insights-resources/articles/2016/lending-platforms-fca-offers-client-money-simplifCrowdfunding platforms offering regulated peer to peer (P2P) loans and unregulated business to business (B2B) loans? The Financial Conduct Authority (FCA) is proposing to change how you hold client money in your accounts.Thu, 28 Jan 2016 00:00:00 Ze0616d3c-16cf-4936-9737-c5abe50be21fhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2016/alltech-acquires-masterfeedsCounsel to Alltech on its acquisition of Masterfeeds, creating one of Canada’s largest animal nutrition companies.Fri, 08 Jan 2016 00:00:00 Z6e2394de-6279-4787-a8aa-7e72ca90470bhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2015/realstar-apartment-management-launches-rap-3-fundOn December 22, 2015, Realstar Apartment Management completed the initial closing and $235 million capitalization of its Realstar Apartment Partnership 3 (“RAP 3”) Fund.Tue, 22 Dec 2015 00:00:00 Z82a3bcd5-4b60-41c6-bd23-c9fc7dd713dehttps://gowlingwlg.com/en-CA/insights-resources/client-work/2015/amica-mature-lifestyles-acquired-by-baybridge-seniOn December 18, 2015, Amica Mature Lifestyles Inc. (“Amica“) (TSX: ACC) and BayBridge Seniors Housing Inc. (“BayBridge“) announced the completion of the acquisition of Amica by BayBridge.Fri, 18 Dec 2015 00:00:00 Z3d43611d-15e5-4941-a521-e199d83af23fhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2015/premier-exhibitions-closes-cross-border-merger-witOn November 1, 2015, Premier Exhibitions, Inc. (NASDAQ: PRXI) (Premier) acquired the outstanding shares of Dinoking Tech Inc. (Dinoking) through the issuance of Premier shares and shares exchangeable for Premier shares, following shareholder approval on October 29.Sun, 01 Nov 2015 00:00:00 Zc3a82c0a-8ce8-48cf-ac86-b25ed28d1c2ahttps://gowlingwlg.com/en-ca/insights-resources/client-work/2015/crh-canada-group-acquires-pro-mix-beton-and-pro-miOn October 31, 2015, CRH Canada Group Inc. closed a hybrid transaction involving a share purchase and an asset purchase transaction valued at $8 million with Pro-Mix Béton Inc. and Pro-Mix Transport Inc.Sat, 31 Oct 2015 00:00:00 Z13ae94c9-ff1e-48d3-adfe-9dfe112801cahttps://gowlingwlg.com/en-ca/insights-resources/client-work/2015/the-pic-group-acquired-by-trigo-groupOn October 30, 2015, TRIGO Group, an international provider of operational quality solutions headquartered in France and a portfolio company of UK-based IK Investment Partners Limited, acquired the Canadian and US operations of The PIC Group Inc.Fri, 30 Oct 2015 00:00:00 Zb4dc7579-ba1a-4bc7-a0c8-4338b1c3aca2https://gowlingwlg.com/en-ca/insights-resources/articles/2015/french-tax-authorities-on-reimbursement-claimsOur experts address the FTA's comments and what they could mean for you.Fri, 23 Oct 2015 00:00:00 Z93728304-44fe-4565-a163-a457bb98bd42https://gowlingwlg.com/en-ca/insights-resources/articles/2015/the-3-tax-filing-requirements-traps-to-avoidThe ownership of a French residential property through a foreign company/entity triggers 3% tax issues that purchasers are often unaware of.Mon, 19 Oct 2015 00:00:00 Z966626b7-2ed4-4cf4-9884-ddd7fdef7eb8https://gowlingwlg.com/en-CA/insights-resources/client-work/2015/novera-therapeutics-announces-collaboration-with-jOn October 14, 2015, The Ontario Institute for Cancer Research ("OICR") and Novera Therapeutics Inc. announced a collaboration with Janssen Biotech, LLC, a pharmaceutical company of Johnson & Johnson, to accelerate the development of promising small molecule drug candidates for haematological cancers.Wed, 14 Oct 2015 00:00:00 Zd0aadc71-1acb-44ef-9e6c-90a65f3dd383https://gowlingwlg.com/en-ca/insights-resources/articles/2015/social-contributions-no-longer-applicable-to-non-fSocial contributions may no longer apply to non French-tax residents. Our French tax experts take a closer look.Mon, 28 Sep 2015 00:00:00 Za76aa9e7-a6ff-4322-a793-e06dad448c6bhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2015/pfingsten-partners-portfolio-company-acquires-cutOn September 1, 2015, Burton Saw and Supply Holdings, a manufacturer and distributor of consumable products and equipment to saw mills and wood product manufacturers, acquired the assets of Cut Technologies.Tue, 01 Sep 2015 00:00:00 Z21239265-3d87-4310-ab74-738dff06fb97https://gowlingwlg.com/en-CA/insights-resources/client-work/2015/vubiquity-completes-cross-border-acquisition-of-leOn August 31, 2015, VUBIQUITY, the leading global provider of premium content services, announced the acquisition of Juice Worldwide.Mon, 31 Aug 2015 00:00:00 Z831989f6-1bc0-4892-a698-f0ee8970a13dhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2015/korean-private-equity-fund-commits-us750-millionGowlings advised a Korean private equity fund in connection with its July 6, 2015 aggregate commitment of US$750 million to a fund formed with one of Canada’s largest pension funds.Wed, 01 Jul 2015 00:00:00 Z1f58ee5e-dbf9-4875-bc2e-bcfe09190cbahttps://gowlingwlg.com/en-CA/insights-resources/client-work/2015/g-k-services-acquires-sanilocOn July 20, 2015, G&K Services Inc., a North American leader in uniform rental and facility products, acquired assets of Saniloc Inc.Wed, 01 Jul 2015 00:00:00 Z95130c04-a6dc-4aa9-8a36-1206b7bc3941https://gowlingwlg.com/en-ca/insights-resources/articles/2015/forced-audit-disclosure-of-uncertain-tax-positionsMNR v BP Canada Energy Company is the first Canadian case dealing with whether a taxpayer's subjective view of its tax filing position must be disclosed to the Minister of National Revenue ("Minister") during an audit.Wed, 01 Jul 2015 00:00:00 Z9b8a0695-1392-4e94-9ac1-eb1dbcb93c4ahttps://gowlingwlg.com/en-ca/insights-resources/articles/2015/manning-a-ghost-ship-tax-court-allows-undischargeIn Paul L. Schnier v. Her Majesty the Queen,[1] the Tax Court of Canada (TCC) dismissed a motion to quash an appeal brought on the basis that the appellant did not, as an undischarged bankrupt, have the capacity, pursuant to Section 71 of the Bankruptcy and Insolvency Act, to deal with property, including the ability to bring an appeal.Wed, 01 Jul 2015 00:00:00 Z23dff794-4993-442e-ab50-92743d0a6d36https://gowlingwlg.com/en-ca/insights-resources/articles/2015/why-you-should-voluntarily-disclose-your-offshoreIn recent years, the popularity of the Canada Revenue Agency's voluntary disclosures program – which enables taxpayers to correct any mistakes or omissions in their previous tax filings – has ballooned.Wed, 01 Jul 2015 00:00:00 Z50aa1e9c-53a6-4b5d-9b21-72200dacc9fchttps://gowlingwlg.com/en-ca/insights-resources/articles/2015/tension-and-trends-in-tax-driven-rectification-grThe Ontario Court of Appeal's decision in Juliar et al v Canada (Attorney General)[1] has long been the leading Ontario case on rectification of tax mistakes. Some commentators have observed that the law on rectification in the context of tax mistakes may be developing independently from, and more broadly than, rectification generally.Wed, 01 Jul 2015 00:00:00 Z258264ea-eba1-4a79-995d-67c0225403a9https://gowlingwlg.com/en-ca/insights-resources/articles/2015/buying-and-owning-a-french-residential-property-inIn this alert, we look at the tax aspects of buying and owning a property in France in 2015 in line with the most recent tax changes. We also consider some important trusts and French tax residence issues which may be relevant to purchasers.Mon, 29 Jun 2015 00:00:00 Z1603889f-d0bd-40a9-af3b-36e7e2da87c6https://gowlingwlg.com/en-ca/insights-resources/articles/2015/minimalist-approachChris Nyland sets out the facts behind the Royal College of Paediatrics' purchase of a new property, and explains why the TOGC should be an issue that concerns us all. This article was originally published in Tax Adviser in May 2015.Mon, 08 Jun 2015 00:00:00 Zd179fea6-3cbf-4a1b-86e1-7d296dde5729https://gowlingwlg.com/en-CA/insights-resources/client-work/2015/blackhawk-network-acquires-achievers-corpOn June 30, 2015, Blackhawk Network Holdings, Inc. (NASDAQ: HAWK) announced that it had completed its previously announced acquisition of Achievers Corp.Mon, 01 Jun 2015 00:00:00 Za6ed1db7-798d-4e3c-ba9a-086315683cbchttps://gowlingwlg.com/en-CA/insights-resources/client-work/2015/the-carlyle-group-completes-us210-5-million-commoOn June 5, 2015, The Carlyle Group L.P., an entity part of the Carlyle Group issued and sold 7,000,000 common units representing Limited Partnership Interests for proceeds of US$210.5 million.Mon, 01 Jun 2015 00:00:00 Z6057c1db-91a1-4087-9c7a-cb34f3953caehttps://gowlingwlg.com/en-CA/insights-resources/client-work/2015/manitok-energy-completes-61-5-million-asset-acquiOn June 12, 2015, Manitok Energy Inc. (TSXV: MEI) announced that it had closed its previously announced acquisition of certain petroleum and natural gas assets in the Wayne area of southeast Alberta for a total cash consideration of $61.5 million prior to transaction costs and customary closing adjustments.Mon, 01 Jun 2015 00:00:00 Zb8e3cdb2-7ec1-4e46-a8fe-68d420e28a0bhttps://gowlingwlg.com/en-ca/insights-resources/articles/2015/relationship-between-tax-treaties-and-domestic-taxA common mistake when analyzing the tax implications of a cross border transaction is to jump too quickly to the ramifications of a tax treaty without first having a clear handle on the tax implications under the Income Tax Act (Canada) (ITA).Mon, 01 Jun 2015 00:00:00 Zbaddffe4-b57f-43cc-aff8-7c995e559dbchttps://gowlingwlg.com/en-ca/insights-resources/articles/2015/limited-but-welcome-relief-for-the-cross-border-emThe 2015 federal Budget included a proposal to reduce the compliance burden of sending non-resident employees to work in Canada for short durations as of Jan. 1, 2016. While the proposal is welcome, the measures are somewhat limited and may not provide relief in all circumstances, including some fairly common scenarios.Mon, 01 Jun 2015 00:00:00 Zaaafb53d-52f8-4089-8358-7d04c23584c4https://gowlingwlg.com/en-ca/insights-resources/articles/2015/interest-deductibility-recent-developmentsThe Canadian tax regime generally allows for the deductibility of interest on borrowed money or indebtedness incurred for the purposes of earning income from a business or property.Mon, 01 Jun 2015 00:00:00 Z81285aa8-4eb7-4358-8d22-4415742ece5dhttps://gowlingwlg.com/en-ca/insights-resources/articles/2015/enterprise-tax-reliefsThis article was written by tax specialist, director Zoe Fatchen, and was first published by The Tax Journal on 28 May 2015.Thu, 28 May 2015 00:00:00 Ze5419749-e8ac-4c43-a616-75f72c2bd3e0https://gowlingwlg.com/en-ca/insights-resources/client-work/2015/orbite-aluminae-completes-15-million-public-offerOn May 6, 2015, Orbite Aluminae Inc. (TSX: ORT) (OTCQX: EORBF) announced that, further to its press release of April 6, 2015 announcing closing of the first portion of its public offering of units in the amount of $10,000,000, Euro Pacific Canada Inc., the underwriter under the public offering, had exercised in full its option to purchase an additional $5,000,000 of units, bringing the aggregate gross proceeds for the public offering to $15,000,000.Thu, 28 May 2015 00:00:00 Zc2639718-12a8-4591-b74a-5118e39bd11fhttps://gowlingwlg.com/en-ca/insights-resources/articles/2015/capital-gains-realised-by-non-french-tax-residentsSince 1 January 2015, the tax rate applicable to capital gains realised on real estate assets by persons who for tax purposes are non-residents of the European Union or the European Economic Area, has been reduced from 33.33% to 19% (article 60 of the second Amending Finance Law for 2014).Tue, 05 May 2015 00:00:00 Z4a8ba66f-69e5-40b4-a2c7-079d5fef359chttps://gowlingwlg.com/en-CA/insights-resources/client-work/2015/kuangchi-science-invests-17-million-in-solar-shipOn May 29, 2015, KuangChi Science Ltd. (SEHK: 439) completed its investment of $17 million in Solar Ship Inc. for a 32.58% interest in the company.Fri, 01 May 2015 00:00:00 Z6d72b169-e9c5-48e4-a881-148cae3a3396https://gowlingwlg.com/en-CA/insights-resources/client-work/2015/the-blackstone-group-completes-million-notesOn May 19, 2015, Blackstone Holdings Finance Co. L.L.C., an entity part of the Blackstone Group, L.P., issued and sold €200,000,000 aggregate principal amount of 2.0% Senior Notes due 2025.Fri, 01 May 2015 00:00:00 Z6d20d1a8-4a11-47f1-baec-eb14eed4969dhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2015/voyageur-airways-acquired-by-chorus-aviationOn May 1, 2015, Chorus Aviation Inc. announced that it had successfully closed its acquisition of 519222 Ontario Limited, a holding company that owns Voyageur Airways Limited and its related companies, a leading provider of specialized aviation services with international operations.Fri, 01 May 2015 00:00:00 Z72c59271-5b03-4c6a-bd9d-ded9fcd31ac8https://gowlingwlg.com/en-ca/insights-resources/client-work/2015/yangarra-resources-closes-20-million-bought-dealOn May 21, 2015, Yangarra Resources Ltd. (TSX: YGR) completed its "bought deal" financing, by way of a short form prospectus, for the sale of common shares and common shares issued on a "flow through" basis in respect of "Canadian development expenses" and “Canadian exploration expenses” within the meaning of the Income Tax Act (Canada), for aggregate gross proceeds of approximately $20 million.Fri, 01 May 2015 00:00:00 Z547f126b-565a-42bd-9d31-ae464980cb40https://gowlingwlg.com/en-ca/insights-resources/client-work/2015/sterigenics-international-closes-recapitalizationOn May 18, 2015, Sterigenics International announced that it had closed a recapitalization with an affiliate of Warburg Pincus and private equity firm GTCR.Fri, 01 May 2015 00:00:00 Z634f55c6-5dcb-4455-8ebf-07491765c346https://gowlingwlg.com/en-CA/insights-resources/client-work/2015/firm-capital-mortgage-investment-corporation-closeOn April 17, 2015, Firm Capital Mortgage Investment Corporation (the “Corporation”) (TSX: FC) announced that it had closed its previously announced offering of $25,000,000 aggregate principal amount of 5.30% convertible unsecured subordinated debentures due May 31, 2022 of the Corporation at a price of $1,000 per Debenture.Fri, 17 Apr 2015 00:00:00 Z25952757-bb1d-4fb0-8f1e-06571858898chttps://gowlingwlg.com/en-ca/insights-resources/articles/2015/franco-german-tax-treaty-amendment-of-31-march-20After the amendment to the Franco-Luxembourg Tax Treaty of September 2014, it is now the turn of the Franco-German Tax Treaty, with an amendment concluded on 31 March 2015.Mon, 13 Apr 2015 00:00:00 Zfdc62315-acb0-42a2-a0bf-20ae7bcdc94bhttps://gowlingwlg.com/en-ca/insights-resources/articles/2015/convention-fiscale-franco-allemande-avenant-du-3Après la Convention franco-luxembourgeoise, (septembre 2014), c'est au tour de la Convention fiscale franco-allemande de faire l'objet d'un avenant, conclu le 31 mars 2015.Mon, 13 Apr 2015 00:00:00 Z193d12bf-2905-465b-88c7-8244fba8403ehttps://gowlingwlg.com/en-CA/insights-resources/client-work/2015/georgian-partners-closes-growth-equity-fund-raisinOn April 9, 2015, Georgian Partners completed the final closing for its second growth equity fund, Georgian Partners Growth Fund II (the “Fund”), with $200 million in committed capital.Thu, 09 Apr 2015 00:00:00 Z667721fc-8702-4dcb-a91f-399726163352https://gowlingwlg.com/en-CA/insights-resources/client-work/2015/paramount-gold-and-silver-acquired-by-coeur-miningOn April 17, 2015, Paramount Gold and Silver Corp. (NYSE MKT: PZG) (TSX: PZG) and Coeur Mining, Inc. (NYSE: CDE) completed their plan of merger, pursuant to which Coeur acquired all of the issued and outstanding shares of common stock of Paramount and the San Miguel Project.Wed, 01 Apr 2015 00:00:00 Zb23e8569-0c83-4033-bf1d-793ff091993fhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2015/the-blackstone-group-completes-us350-million-noteOn April 27, 2015, Blackstone Holdings Finance Co. L.L.C., an entity part of the Blackstone Group, L.P., issued and sold US$350,000,000 aggregate principal amount of 4.45% Senior Notes due 2045.Wed, 01 Apr 2015 00:00:00 Za162f9f1-e47e-45dd-85f5-a732d1a9e396https://gowlingwlg.com/en-CA/insights-resources/client-work/2015/chango-acquired-by-rubicon-project-in-cross-borderOn April 27, 2015, Rubicon Project (NYSE: RUBI), a global technology company leading the automation of advertising, announced the completion of the acquisition of Chango Inc.Wed, 01 Apr 2015 00:00:00 Z075e6303-2246-4162-a29f-6a607ad51f85https://gowlingwlg.com/en-CA/insights-resources/client-work/2015/gtcr-sells-fundtech-in-us1-25-billion-cross-bordeOn April 30, 2015, Fundtech, a leading global provider of global payments and transaction banking software and a portfolio company of private equity firm GTCR, was acquired by DH Corporation (TSX: DH) for cash consideration of approximately $1.25 billion.Wed, 01 Apr 2015 00:00:00 Zce74e0f6-3cc0-4152-9e59-054434e88cbbhttps://gowlingwlg.com/en-ca/insights-resources/articles/2015/unnecessary-complexity-the-new-back-to-back-loanThe modified back-to-back loan measures proposed in the 2014 Budget were enacted on Dec. 17, 2014. These measures are intended to address situations where certain non-residents try to avoid the application of the thin capitalization and interest-withholding tax rules by making back-to-back loans to Canadian corporations and trusts through third-party intermediaries rather than making those loans directly to the Canadian taxpayer.Wed, 01 Apr 2015 00:00:00 Z1b60dfa5-6021-46e6-83de-6ede02173c55https://gowlingwlg.com/en-ca/insights-resources/client-work/2015/tandem-expansion-fund-acquires-majority-interest-iOn April 2, 2015, Averna announced that Tandem Expansion Fund had acquired a majority interest in the company.Wed, 01 Apr 2015 00:00:00 Z30b00df2-97a2-4afa-8897-c26107c79affhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2015/cardinal-energy-and-pinecrest-energy-close-plan-ofOn April 15, 2015, Cardinal Energy Ltd. (TSX: CJ) and Pinecrest Energy Inc. (TSXV: PRY) announced the completion of the previously announced reorganization of the business of Pinecrest.Wed, 01 Apr 2015 00:00:00 Z76eb587f-0377-4b56-9f3d-572c440d4295https://gowlingwlg.com/en-ca/insights-resources/client-work/2015/mirexus-announces-investment-from-goddard-enterpriOn April 10, 2015, Mirexus Biotechnologies Inc. announced a new investment from Goddard Enterprises Ltd. (“GEL”) of Barbados.Wed, 01 Apr 2015 00:00:00 Z1ccbc293-4cb3-4b08-889c-9bb7dc61cbb8https://gowlingwlg.com/en-ca/insights-resources/articles/2015/capital-gains-tax-sale-and-french-real-estateAt the end of last year, we shared some positive and interesting developments regarding French capital gains tax (CGT) applicable to non-French tax residents.Wed, 04 Mar 2015 00:00:00 Z429f3324-8116-4095-8f29-8e72c714ac65https://gowlingwlg.com/en-CA/insights-resources/client-work/2015/pension-fund-investors-commit-30-million-to-canadGowlings advised two Canadian pension fund investors in connection with their March 31, 2015 aggregate commitment of $30 million to a Canadian buyout fund.Sun, 01 Mar 2015 00:00:00 Z9d2f3562-b3e7-4a11-845c-6f995b78fe15https://gowlingwlg.com/en-ca/insights-resources/articles/2015/concerns-about-going-concernsA new tribunal case throws fresh light on the need to take a careful and considered approach to real estate dealings - and not to rely on an overly-mechanistic interpretation of VAT law and HMRC guidance. But, as happens all too often with VAT case law, it raises as many questions as it answers.Mon, 16 Feb 2015 00:00:00 Z44cd4771-88fc-4457-8f84-433bb9c82384https://gowlingwlg.com/en-ca/insights-resources/articles/2015/update-on-vat-on-pension-fund-costs-and-recoveryLast year, HMRC issued two Briefs (Nos. 43 and 44) setting out more information on its policy on the VAT treatment of pension scheme costs.Tue, 03 Feb 2015 00:00:00 Z2adce680-09aa-4df3-a4c7-c0e7a3d5056fhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2015/caisse-de-depot-sponsors-110-million-fonds-manufaGowlings advised Caisse de dépôt et placement du Québec in connection with the formation and closing on February 20, 2015, of Fonds manufacturier québécois II S.E.C.Sun, 01 Feb 2015 00:00:00 Z526d1299-8377-40e1-89a6-e19154c0f25fhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2015/interrent-reit-closes-75-million-bought-deal-finaOn February 19, 2015, InterRent Real Estate Investment Trust (TSX: IIP.UN) announced the closing of its previously announced public offering of 11,719,000 trust units from treasury, at a price of $6.40 per unit for gross proceeds of $75,001,600.Sun, 01 Feb 2015 00:00:00 Z5566a3ee-bb49-4e98-bb78-3a701238c16chttps://gowlingwlg.com/en-ca/insights-resources/articles/2015/government-stamps-its-intentions-on-schemes-of-arrJulian Henwood, M&A partner at Wragge Lawrence Graham & Co, casts an analytical eye over the draft Companies Act 2006 (Amendment of Part 17) Regulations 2015 that will prevent the use of cancellation schemes of arrangement to effect a takeover and predicts that increased transaction costs occasioned by the stamp duty charge applicable to certain takeovers effected by way of a transfer will not result in fewer takeovers.Thu, 29 Jan 2015 00:00:00 Z34467731-2017-4204-a09d-554407796d15https://gowlingwlg.com/en-ca/insights-resources/client-work/2015/pfingsten-partners-acquires-burton-saw-and-supplyOn January 8, 2015, private equity firm Pfingsten Partners completed its acquisition of Burton Saw and Supply Company.Thu, 08 Jan 2015 00:00:00 Z8ff0cbad-83c6-4f44-b53d-6a1bfec47703https://gowlingwlg.com/en-ca/insights-resources/articles/2015/current-issues-in-the-taxation-of-real-estateWragge Lawrence Graham & Co's tax experts bring you the latest tax law issues and provide action points to help you and your organisation.Tue, 06 Jan 2015 00:00:00 Z5cbfaf52-2786-4337-af94-adcad1e07296https://gowlingwlg.com/en-CA/insights-resources/client-work/2015/mariana-resources-and-aegean-metals-group-close-crEffective January 16, 2015, Mariana Resources Limited (AIM: MARL) acquired all of the issued and outstanding shares of Aegean Metals Group Inc.Thu, 01 Jan 2015 00:00:00 Z8108ba1b-70ab-4c81-bbd9-59951de23dc8https://gowlingwlg.com/en-CA/insights-resources/client-work/2015/state-farm-sells-canadian-insurance-operations-toOn January 1, 2015, State Farm completed the sale of its Canadian businesses in property and casualty and life insurance, as well as its Canadian mutual fund, loan and living benefits companies, to Desjardins Group, the leading cooperative financial group in Canada.Thu, 01 Jan 2015 00:00:00 Z80ecee98-6fbb-4c30-8f15-8e2b0648f057https://gowlingwlg.com/en-ca/insights-resources/client-work/2015/riley-resources-completes-cpc-initial-public-offerOn January 8, 2015, Riley Resources Corp. (TSXV: RLY.P) completed its initial public offering pursuant to a Prospectus dated December 19, 2014 filed with the British Columbia, Alberta and Ontario Securities Commissions.Thu, 01 Jan 2015 00:00:00 Z19919803-0b39-4886-bd11-4cea44c48ca0https://gowlingwlg.com/en-ca/insights-resources/articles/2014/property-update-november-december-2014This month our real estate experts look at rights to light; buyer unable to grant leaseback to seller ahead of completion of sale and mortgage; repair breach prevents exercise of tenant's lease break clause and when is a lease assignment not a lease assignment?Mon, 15 Dec 2014 00:00:00 Z03612ad1-3437-4e38-ac02-edba654e661fhttps://gowlingwlg.com/en-ca/insights-resources/articles/2014/stamp-duty-land-tax-sdlt-the-slab-fallsResidential Stamp Duty Land Tax (SDLT) (i.e. SDLT on deals relating to interests in/over dwellings and their curtilages) has changed.Fri, 12 Dec 2014 00:00:00 Zbb2b13b2-8e94-4aab-977e-b6981cdde398https://gowlingwlg.com/en-ca/insights-resources/articles/2014/permanent-establishment-widening-the-netPermanent establishment (PE) is a key concept in determining which country can tax the profits of a business established in one country and operating from another. It is defined in the majority of double taxation treaties as, broadly, a fixed place through which the business is wholly or partly carried on.Fri, 05 Dec 2014 00:00:00 Zefb27796-14da-4884-87a7-8bf3daa74425https://gowlingwlg.com/en-ca/insights-resources/articles/2014/pay-now-prove-it-later-challenging-accelerated-pFinance Act 2014 gifted to HM Revenue and Customs (HMRC) two powerful new weapons for the enforcement and collection of tax: 'follower notices' and 'accelerated payment notices'.Thu, 30 Oct 2014 00:00:00 Z863ca6c6-291d-44f9-a2ca-0ef9cfb85367https://gowlingwlg.com/en-ca/insights-resources/articles/2014/real-estate-vat-planning-is-an-abuse-of-rightsIf you are setting up or buying into a VAT planning scheme (or you have done so in the past), then a recent decision of the Upper Tribunal (Tax & Chancery Chamber) (UT) might lead you to question the wisdom of that decision.Thu, 30 Oct 2014 00:00:00 Z34094d99-eab4-4bd7-8350-c89da4ff8bb3https://gowlingwlg.com/en-ca/insights-resources/articles/2014/the-marzen-decision-a-typical-example-of-bepsOn June 10, 2014, the Tax Court of Canada (TCC) delivered its most recent decision on transfer pricing, one which involved a Barbados structure.Sun, 19 Oct 2014 00:00:00 Zb47582c9-d556-4d4e-a429-f91e29ccd28bhttps://gowlingwlg.com/en-ca/insights-resources/articles/2014/owning-a-french-residential-property-in-france-soFailure to adopt the right structure of ownership on French properties can have costly tax consequences.Thu, 09 Oct 2014 00:00:00 Zb724224d-c862-4c26-92eb-3d8db3c2c880https://gowlingwlg.com/en-CA/insights-resources/client-work/2014/printeron-acquired-by-samsung-electronicsOn September 2, 2014, global technology leader Samsung Electronics Co., Ltd. announced its acquisition of PrinterOn®, a pioneer in mobile cloud printing solutions based in Ontario and the world's leading enterprise-grade mobile printing platform.Tue, 02 Sep 2014 00:00:00 Ze79ff35b-72d2-49aa-9a77-0a959b80c61bhttps://gowlingwlg.com/en-ca/insights-resources/articles/2014/the-statutory-residence-test-a-reminderIf you are regarded as a non-UK resident, you will not have to pay UK income tax on non-UK source income or capital gains tax on both UK and non-UK assets.Wed, 06 Aug 2014 00:00:00 Z798df149-d2df-46fe-84a8-917be5192032https://gowlingwlg.com/en-ca/insights-resources/articles/2014/mckesson-canada-corporation-v-the-queenThere are very few Canadian tax cases involving transfer pricing. As such, the Tax Court of Canada's decision in McKesson Canada Corporation v. The Queen 1 came as a welcome addition to the jurisprudence.Mon, 19 May 2014 00:00:00 Zb08a688f-3486-4c1f-a8ae-8918d18f6a97https://gowlingwlg.com/en-ca/insights-resources/articles/2014/conrad-black-resident-here-resident-thereIn a recent Tax Court of Canada decision, Conrad Black v. The Queen, 2014 TCC 12, the Court dealt with the interaction between Canada’s tax treaty dual resident tie-breaker rules and domestic laws in a fact situation where subsection 250(5) did not apply.Thu, 20 Mar 2014 00:00:00 Z1e218e9d-98f9-4342-ad68-a9dfd6f7ac81https://gowlingwlg.com/en-ca/insights-resources/articles/2014/tax-support-for-the-uk-onshore-shale-gas-industryOur experts outline the general tax landscape for oil and gas exploration and the new shale gas regime.Mon, 20 Jan 2014 00:00:00 Zf768dd28-9a24-4dc7-93c5-feef38d89a9bhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2013/stem-cell-therapeutics-completes-33-million-privaOn December 13, 2013, Stem Cell Therapeutics Corp. (TSXV: SSS) (OTCQX: SCTPF), an immuno-oncology company developing cancer stem cell-related therapeutics, announced that it had raised gross proceeds of $33 million through a private placement of units.Fri, 13 Dec 2013 00:00:00 Z46d489f8-159d-4718-a6bf-688bfce36727https://gowlingwlg.com/en-ca/insights-resources/articles/2013/new-limitation-on-benefits-provisions-in-canada-sCanada's tax treaties with foreign countries routinely include a variety of anti-abuse or treaty shopping provisions aimed at those structures or transactions utilized to improperly access treaty benefits.Mon, 01 Jul 2013 00:00:00 Z038a3832-301a-4370-98c4-0eb697cce9e8https://gowlingwlg.com/en-CA/insights-resources/client-work/2013/stem-cell-therapeutics-closes-unit-offeringOn March 15, 2013, Stem Cell Therapeutics Corp. (TSXV: SSS), a life sciences company developing stem cell-related technologies, announced that it had closed its previously announced prospectus offering of units for the aggregate gross proceeds of $3,078,750. Euro Pacific Canada Inc. acted as the agent for the offering.Fri, 15 Mar 2013 00:00:00 Zecc979fa-d292-4a83-bfde-cf91447170fahttps://gowlingwlg.com/en-ca/insights-resources/articles/2013/canada-s-new-tax-treaty-with-hong-kong-10-key-aspOn Nov. 11, 2012, after relatively swift negotiations, the Government of Canada signed a tax treaty with the Government of the Hong Kong Special Administrative Region of China (the “Treaty”). The Treaty with Hong Kong is a positive development given that Canada entered into a similar tax treaty with China in 1986 (the “Canada-China Treaty”) and that a relatively large number of residents of Hong Kong have social and economic ties with Canada.Tue, 01 Jan 2013 00:00:00 Ze97cdc2c-bc9e-4a24-a417-bd00ebae15ffhttps://gowlingwlg.com/en-ca/insights-resources/client-work/2012/nextera-energy-in-joint-venture-with-enbridge-andOn September 24, 2012, NextEra Energy Canada, ULC (NYSE: NEE), Enbridge Inc. (TSX: ENB) (NYSE: ENB) and Borealis Infrastructure announced that they had filed for regulatory approval to allow Enbridge and Borealis to acquire interests in NextEra Energy Canada's subsidiary, Upper Canada Transmission, Inc.Mon, 24 Sep 2012 00:00:00 Z658f4c9b-ba2c-4b55-92ea-5b7b5207622dhttps://gowlingwlg.com/en-ca/insights-resources/articles/2012/the-berry-ratio-why-it-should-rarely-be-used-in-tTransfer pricing economists must consider various transfer pricing methodologies when assigning intercompany profits to related parties.Sun, 01 Apr 2012 00:00:00 Zdc31e989-cc45-40d7-a7f0-73fd8adccf56https://gowlingwlg.com/en-ca/insights-resources/articles/2012/outdated-provision-of-canadian-income-tax-act-taxeTax is constantly evolving, and sometimes obsolete provisions need to be pruned. While the Federal government regularly amends the Income Tax Act (Canada) (Act) in an effort to preserve the tax base and curb abuse of the Act by taxpayers, impetus for changing or abolishing provisions of the Act may come from taxpayers and their tax advisors who perceive such provisions to be obsolete, outdated or unfair.Wed, 01 Feb 2012 00:00:00 Z95bcef25-4fde-4348-8a62-3561cafde64ehttps://gowlingwlg.com/en-ca/insights-resources/articles/2011/the-perils-of-an-obsolete-tax-provisionTaxation is an area of the law in constant evolution. Whereas legislature keeps amending the Income Tax Act (Canada) (the Act) in an effort to preserve the tax base and curb abuse of the Act by taxpayers, impetus for changing or abolishing provisions of the Act often also comes from taxpayers where such provisions are perceived to be obsolete, outdated or unfair.Thu, 15 Dec 2011 00:00:00 Z29e27960-fc52-47c5-9aa9-1bbe751dc38fhttps://gowlingwlg.com/en-CA/insights-resources/client-work/2011/tax-court-of-canada-issues-decision-on-tax-assesseOn May 24, 2011, in Dugan v. The Queen, 2011 TCC 269, the Tax Court of Canada issued a decision in respect of tax assessed on employment income held on-reserve by First Nations members.Tue, 24 May 2011 00:00:00 Z936a2c5a-57e7-441b-8e30-c777d6df86echttps://gowlingwlg.com/en-ca/insights-resources/articles/2011/developments-regarding-article-xiii-8The purpose of this article is to provide an update on current developments at the Canadian Competent Authority regarding Article XIII(8) of the Canada-United States Tax Convention.Thu, 05 May 2011 00:00:00 Z1a9a6b70-bb48-4d9f-882a-225b544be5d8https://gowlingwlg.com/en-ca/insights-resources/articles/2011/canada-us-tax-treatyThe 5th Protocol to the Canada-United States Tax Convention (1980) (the Treaty), which entered into force on December 15, 2008, introduced several significant and highly anticipated changes to the Treaty.Wed, 04 May 2011 00:00:00 Ze1d3ae45-c41b-4581-97e2-6251db74ef01https://gowlingwlg.com/en-ca/insights-resources/articles/2011/canada-switzerland-double-tax-treaty-to-meet-oecdOn October 22, 2010 the Government of Canada and Swiss Federal Council signed a protocol (“Protocol”) to amend the 1997 Convention between Canada and Switzerland for the Avoidance of Double Taxation with Respect to Taxes on Income and on Capital (“Convention”).Mon, 02 May 2011 00:00:00 Z087e1ae3-c31f-4875-ba99-c559527006b1https://gowlingwlg.com/en-ca/insights-resources/articles/2010/restrictions-on-input-tax-credits-for-hst-on-energBritish Columbia and Ontario are replacing their provincial sales taxes and the federal Goods and Services Tax (GST) with a single Harmonized Sales Tax (HST) from July 1, 2010. The federal legislation amending the Excise Tax Act received Royal Assent on December 15, 2009.Fri, 19 Mar 2010 00:00:00 Zc2f7a56e-537b-400d-98d7-6d4e982bfe60https://gowlingwlg.com/en-ca/insights-resources/articles/2009/gaar-case-comment-lehigh-cement-tax-courtTue, 03 Nov 2009 00:00:00 Z249f4279-714f-460a-ac58-4a9adc947bd5https://gowlingwlg.com/en-ca/insights-resources/articles/2009/mr-lipson-goes-to-ottawa-clarifying-interest-dedOn January 8, 2009 the Supreme Court of Canada released its decision in Lipson. While the appellant in this case was not ultimately successful in obtaining the benefit of his spouse's interest deduction, this decision does provide a measure of comfort for other taxpayers in that Singleton-type interest deductibility tax planning appears to be alive and well.Thu, 22 Jan 2009 00:00:00 Z4db0b0ad-f722-4869-9970-84369da95b38https://gowlingwlg.com/en-ca/insights-resources/articles/2008/interest-deductibility-uncertain-in-light-of-lipsThe Income Tax Act (Canada) distinguishes between interest paid or payable by taxpayers on account of a business venture and a personal venture. Essentially, interest expense incurred on a business loan will generally be deductible to the taxpayer or, in some cases, may be capitalized.Wed, 10 Dec 2008 00:00:00 Z05c5b0c9-5c64-4001-b27d-0141e24af89dhttps://gowlingwlg.com/en-ca/insights-resources/articles/2008/moving-to-the-united-states-tax-consequences-andMoving to the United States may raise all sorts of concerns for individuals resident in Canada, not the least of which are the potential tax consequences to such a move. There are, however, significant planning opportunities available to potentially mitigate such tax consequences and even provide further tax relief in the future.Sun, 15 Jun 2008 00:00:00 Z1fef77af-d46c-4c8c-bd63-684069ee36b9https://gowlingwlg.com/en-ca/insights-resources/articles/2008/the-general-anti-avoidance-rule-are-we-moving-awaThe General Anti-Avoidance Rule (the "GAAR"), contained in section 245 of the Income Tax Act (Canada) (the "Act"), is a provision which allows the Canada Revenue Agency ("CRA") to redetermine the tax consequences of a transaction(s) entered into by a taxpayer in an effort to deny the tax benefit(s) otherwise enjoyed by the taxpayer as a result of entering into the impugned transaction(s).Thu, 01 May 2008 00:00:00 Zf43b0b47-8822-465d-bb5a-7dbf1e1cfcd3https://gowlingwlg.com/en-ca/insights-resources/articles/2008/the-unintended-consequences-of-subsection-256-9This article by Brian Kearl and John McClure was originally published in the April 18, 2008 edition of Taxation Law @ Gowlings.Fri, 18 Apr 2008 00:00:00 Z