On September 23, the Canadian Federal Court of Appeal released the highly anticipated decision in Daishowa-Marubeni. Doug Richardson and Julie D’Avignon of Stikeman Elliott explain why the decision is of particular interest to every mining, energy and forestry company that has bought or sold assets in circumstances where reclamation or reforestation obligations were assumed by the purchaser as part of the sale.
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Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions
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