Canada’s APA programme: an overview

This article provides a brief overview of Canada’s advance pricing arrangement (“APA”) program. Canada’s APA program has existed for over two decades. An 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.

Related briefings

Return to the office: Is your data protected?

With the end of COVID-19 restrictions in sight, many businesses and their employees will be returning to the office within the next few months. While some employers will expect their workforce to be back full-time, others will adopt a hybrid way of working with employees’ time split between the office and home. This presents an array of challenges and issues that employers need to prepare for to ensure safety in the workplace, as well as business continuity. This podcast series discusses the key issues and how employers should address them to make sure their return to the office runs smoothly. In this first episode, Gowling legal director Anna Fletcher is joined by partner Jocelyn Paulley from our Data Protection team. Jocelyn will be discussing the key considerations that employers need to focus on in terms of data protection compliance in this new workplace and how to make sure that confidential information remains secure.

COVID-19 update: Step three of Ontario’s ‘Roadmap to Reopen’ plan presents new challenges for employers

Effective 16 July 2021, Ontario entered ‘Step 3’ of its Roadmap to Reopen. Qualifying businesses (including office workplaces) are now permitted to allow workers to return to the physical workplace, subject to compliance with all applicable health and safety protocols and public health requirements, including local requirements introduced under Regional/Municipal By-laws, Orders issued by local Public Health Units, etc.

Blockchain Webinar Series | Exploring decentralized finance: Understanding the latest trends and legal developments

For sophisticated investors looking for the next opportunity, decentralized finance (DeFi) offers a new way to invest in crypto assets in an on-demand digital world. However, before jumping in with both feet it’s critical to understand what DeFi is, how it works, its potential return on investment and its inherent risks. In this session we explore the burgeoning DeFi landscape, outline key legal considerations and highlight strategies that are currently being offered on various platforms.

Court clarifies Construction Act transition provisions: date of prime contract is key for application of section 87.3

The changes to Ontario’s construction lien legislation continue to make themselves felt with the Ontario Superior Court’s recent decision in Crosslink Transit Solutions Constructors v. Form & Build Supply (Toronto) Inc. (2021 ONSC 3396), which interpreted the transition provisions of the Construction Act, R.S.O. 1990, c. C.30. In the Crosslinx case, the court concluded that the “contract” used to determine whether the old Construction Lien Act or the new Construction Act applies under s.87.3(1)(a) is the prime contract between the owner and the contractor.

Latest Briefings

Our future town and city centres

Post-Covid, how do we revive our urban centres, now and in the future? What does the future hold for work, retail, entertainment and living? These were some of the issues discussed when Birmingham real estate partner, Beth McArdle, chaired a session at the Big Tent Festival 2021 in Coventry. Joining Beth on the panel were: Siraj Ahmed Shaikh, Director of Research at Institute of Future Transport & Cities, Coventry University; Trish Willetts, Coventry BID Director; and Cllr Jim O’Boyle, Cabinet Member for Jobs, Regeneration and Climate Change, Coventry City Council.

Modernisation of the British Virgin Islands trust legislation

Legislative amendments to the British Virgin Islands trust legislation took effect on 9 July 2021 under the Trustee (Amendment) Act, 2021. The reforms introduce welcome improvements to the BVI’s Trustee Act and ensure that the BVI remains a leading offshore jurisdiction for the establishment, administration, and maintenance of trusts.

Canadian travel update: easing border measures for fully vaccinated travellers to Canada

On 20 July 2021, the Government of Canada announced that fully vaccinated U.S. citizens and permanent residents (U.S. Green Card holders) will be allowed to enter Canada as of 9 August 2021 for discretionary travel. As of 7 September 2021, assuming Canada’s epidemiology remains favourable, the federal government will also open the Canadian borders to fully vaccinated travellers from all other countries for discretionary travel.

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Clifford Chance calls in advisers to rethink property strategy

Clifford Chance has started to invite pitches from real estate agents to rethink its property strategy ahead of its City lease end, The Lawyer can reveal. The magic circle firm has hosted virtual meetings to gather ideas and proposals from agencies across London. Sources said the firm is looking to come up with options ahead […]

Mishcon de Reya

Travers wins IPO mandate from Mishcon

Mishcon de Reya has appointed Travers Smith to advise on its anticipated IPO, with the latter securing the mandate over its City rivals. Plans for Mishcon’s initial public offering (IPO) were announced in late April after the firm said its partners had voted “overwhelmingly” in favour of exploring a premium listing. The intention is for […]

Aggreko

Kirkland and Slaughters lead on Aggreko’s £2.3bn sale

Kirkland & Ellis has taken the lead role for the private equity bidders on the £2.3bn buyout of equipment supplier Aggreko. TDR Capital turned to Kirkland yet again after last year seeking the firm’s counsel on its £6.8bn purchase of ASDA. Partners David Holdsworth and Mark Thompson led for TDR and I Squared Capital, with […]

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