Patrick Marley

Patrick Marley

Osler, Hoskin & Harcourt LLP

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Latest Publications


Canada Signs FATCA Intergovernmental Agreement with the United States

Canada and the United States announced on February 5, 2014, that they had signed a long-awaited intergovernmental agreement (Canada–U.S. IGA) that dramatically expands the sharing of tax-related information between the...more

2/7/2014 - Canada FATCA IGAs Income Taxes Tax Evasion

Exchangeable Share Structures Revisited

Exchangeable share structures have been a fixture in structuring cross-border share exchange mergers and acquisitions involving Canadian corporations for decades. Although the Canadian government previously announced plans to...more

6/27/2013 - Canada Cross-Border Dividends Right of Redemption Shareholders Stocks Tax-Deferred Exchanges

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