Heenan Blaikie LLP

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Marie-Claude Bellemare

The Fisheries Act: Federal Rules Concerning the Protection of Fish Habitat Are Amended

On November 25, 2013, important modifications to the Fisheries Act (the “Act”) entered into force further to the adoption, in June 2012, of the Jobs, Growth and Long-term Prosperity Act1 (the “Amending Act”). These amendments…more

Canada, Critical Habitat, Fisheries Act

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Subrata Bhattacharjee

Avoiding Anti-competitive Employee Recruitment Arrangements: The United States Department of Justice Challenges eBay and the Canadian Implications

In 2010, the government of Canada amended the Competition Act, making anti-competitive conspiracies between competitors or potential competitors a per se criminal offence, requiring no evidence of an adverse impact on…more

Cartels, Competition, Conspiracies, DOJ, eBay

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Ali Boroumand

Merger Control in Africa

Created in 1994, the Common Market for Eastern and Southern Africa (the “COMESA”) is an organisation currently comprised of 19 African countries which aim at promoting regional integration in Eastern and Southern Africa (the…more

Acquisitions, Anti-Competitive, COMESA, Cross-Border, Notice Requirements

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Michael Byers

Dealing with Wikipedia Libel: Why a ‘Self-Help’ Remedy is Often the Best Solution

“The Internet is just a world passing around notes in a classroom” - Jon Stewart - Wikipedia is a vast repository of knowledge and information that spans from the trivial to the practical, and includes everything in…more

Defamation, Libel, Self-Help Remedies, Wikipedia

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Lesley Caswell

CIPO Issues New Guidance on Claims to Methods of Medical Use

The Canadian Patent Office recently released a new guidance document on “Examination Practice Respecting Medical Uses”. The guidance document, PN 2013-04, is directed to examiners, and relates to the consideration of claims…more

Canada, Canadian Intellectual Property Office, Medical Devices, Patent-Eligible Subject Matter, Patents

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Mark Edward Davis

Dealing with Wikipedia Libel: Why a ‘Self-Help’ Remedy is Often the Best Solution

“The Internet is just a world passing around notes in a classroom” - Jon Stewart - Wikipedia is a vast repository of knowledge and information that spans from the trivial to the practical, and includes everything in…more

Defamation, Libel, Self-Help Remedies, Wikipedia

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Cendrine Delivré

The Penalties Applicable to Legal Entities Convicted for Corruption under French Law - Are the Administrative Consequences the Only Deterrent?

Under French law, an act of corruption is exclusively subject to criminal liability; there is no administrative liability. Specific rules of administrative laws, however, which provide that a company convicted by a final…more

Administrative Fines, Bribery, Compliance, Corruption, Criminal Sanctions

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Ken Dhaliwal

Prime Time 2013 - News Flash

Today at the Prime Time Conference in Ottawa, Paul Calandra, the Parliamentary Secretary to the Minister of Canadian Heritage and a Member of Parliament announced the implementation of Canada's policy on coproductions…more

Coproduction

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Terry Didus

Optimism in Canada’s Private Equity & Venture Capital Markets

The federal government recently announced that it would be injecting $400 million into the venture capital sector in Canada in 2013. To Canada’s private equity and venture capital community, this comes as welcome news and serves…more

Canada, Investors, Private Equity, Venture Capital

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Anne-Marie Dupont

Aboriginal Law – The Crown’s Duty to Consult and the Involvement of Natural Resources Proponents in the Consultation Process

Natural resources proponents are often deeply involved in consultations with Aboriginal communities that may be affected by their projects. How far can the Crown delegate its constitutional duty to consult Aboriginal people to…more

Aboriginal Issues, Amended Legislation, Canada, Consultation, Duty To Consult

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Ryan Edmonds

Public Institutions, Procedural Fairness and Workplace Investigations

A recent case out of Quebec discusses the level of procedural fairness that may be owed during a workplace investigation for a public institution…more

Canada, Compliance, Harassment, Workplace Investigations

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Cheryl A. Edwards

Corporate Criminal Conviction as Corporate Death Sentence? Court Says Companies Can Be Fined into Bankruptcy for Workplace Accidents

On September 4, 2013, the Court of Appeal for Ontario released its decision in the sentence appeal in R. v. Metron Construction Corporation (“Metron”). Government prosecutors had appealed against the C$200,000 fine Metron…more

Canada, Commercial Bankruptcy, Convictions, Corporate Criminal Fines, Criminal Negligence

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Rod Escayola

Requiring Mandatory Qualifications For Condominium Managers

On July 18, 2013, the Ontario Ministry of Consumer Services issued a news release confirming that Ontario is working to introduce mandatory qualifications for condominium managers…more

Canada, Condominium Associations, New Regulations

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Virginie Fortin

The Cultural Heritage Act, or How to Turn Something Old Into Something New!

Warning! Proceed with care: owners of heritage immovables are now subject to much more stringent rules including with respect to the preservation of the heritage value of their immovables. In the Fall of 2012, a new act was…more

Cultural Heritage Act, Tangible Property

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Marie-Pierre Gauthier

Does The January 1, 2013, Assessment Represent Your Property’s Fair Value?

Dans certaines municipalités, un nouveau rôle triennal pour les années 2013, 2014 et 2015 est entré en vigueur le 1er janvier 2013. Vous avez reçu un avis d’évaluation établissant la nouvelle valeur de votre immeuble. Si vous…more

Fair Market Value, MBRA, Property Tax, Tax Assessment

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Mathieu Gendron

Highlights of Proposed New Mining Tax Regime

On May 6, the Government of Québec announced a new mining tax regime, which, if passed by the National Assembly, will be effective as of January 1, 2014…more

Canada, Mining, Mining Tax, New Legislation

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Adam S. Goodman

Avoiding Anti-competitive Employee Recruitment Arrangements: The United States Department of Justice Challenges eBay and the Canadian Implications

In 2010, the government of Canada amended the Competition Act, making anti-competitive conspiracies between competitors or potential competitors a per se criminal offence, requiring no evidence of an adverse impact on…more

Cartels, Competition, Conspiracies, DOJ, eBay

See All Updates »

Sarah Graves

Public Institutions, Procedural Fairness and Workplace Investigations

A recent case out of Quebec discusses the level of procedural fairness that may be owed during a workplace investigation for a public institution…more

Canada, Compliance, Harassment, Workplace Investigations

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Mark Hines

Rethinking IP Disputes – A Useful Role for International Arbitration

Changing Nature of IP Disputes - Intellectual property (IP) rights have become a truly international phenomenon. Technology is constantly changing. So too are the ways in which businesses seek to protect proprietary…more

Arbitration, Copyright, Cross-Border, Jurisdiction, Licenses

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Barbara Holmes

Second-Hand Smoke In Condominiums

What are the responsibilities of a condominium corporation where second-hand smoke is emanating from one unit to another? Are there additional responsibilities where the complaining owner is allergic to cigarette smoke?…more

Air Pollution, Condominiums, Smokers

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Pierre Huard

Does The January 1, 2013, Assessment Represent Your Property’s Fair Value?

Dans certaines municipalités, un nouveau rôle triennal pour les années 2013, 2014 et 2015 est entré en vigueur le 1er janvier 2013. Vous avez reçu un avis d’évaluation établissant la nouvelle valeur de votre immeuble. Si vous…more

Fair Market Value, MBRA, Property Tax, Tax Assessment

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Jean-François Hudon

Are You in a Conflict of Interest? Outside Business Activities Through the Lens of the Regulator

The Investment Industry Regulatory Organization of Canada (hereafter “IIROC”) published a Rules Notice on June 13, 2013, introducing the new Dealer Member Rule 43 which governs outside business activities and personal financial…more

Canada, Conflicts of Interest, Financial Actvities, New Regulations

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Lesley Kim

Canada Signs Treaty with Hong Kong

On November 11, 2012, Canada signed a tax treaty with Hong Kong (the “Tax Treaty”). Some may find it surprising, given the level of trade between Canada and Hong Kong and the number of Hong Kong residents who have immigrated to…more

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Kosta Kostic

CSA Issues Guidance on Know-Your-Client, Know-Your-Product and Suitability Obligations

HIGHLIGHTS: - Establish policies and procedures for collection of KYC information, meaningful KYP and suitability assessment – provide adequate training to ensure understanding by representatives. - Take…more

Canada, Canadian Securities Administration, Compliance, Know Your Customers

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Melina Koubemba

Merger Control in Africa

Created in 1994, the Common Market for Eastern and Southern Africa (the “COMESA”) is an organisation currently comprised of 19 African countries which aim at promoting regional integration in Eastern and Southern Africa (the…more

Acquisitions, Anti-Competitive, COMESA, Cross-Border, Notice Requirements

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Kenneth Kraft

Indalex: Supreme Court of Canada Decision Released

The Supreme Court of Canada (“SCC”) recently released its much-anticipated decision in the Indalex Limited (“Indalex”) proceedings under the Companies’ Creditors Arrangement Act (the “CCAA Proceedings”). The decision is…more

CCAA, Constructive Trusts, Debtors-in-Possession, Defined Benefit Plans, Employer-Administrators

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Howard Krupat

Contractual Notice Requirements: Not Just a “Technical Defence”

The following conversation is not uncommon at the outset of a construction dispute: Contractor’s Lawyer: “My client is clearly owed millions of dollars for unpaid extra work and delay damages. What is your client’s…more

Breach of Contract, Contractors, Notice Requirements, Subcontractors

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Pierre Langlois

New Mining Act: A Detailed Review

In this article: - New Mining Act – Bill 43 - Exploration Phase - Procedure, Duty to Disclose and Reports - Mining Restrictions - Management of Mining Claims - Extraction Phase…more

Disclosure Requirements, Mineral Exploration, Mining, New Legislation, Penalties

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Denise Lash

Condominium Act 2014? Manager Licensing

The sensational stories in the news over the past few years, about condominium corporations left with depleted reserve funds as a result of fraud by condo managers, has now piqued the government’s and public’s interest in the…more

Condominium Act, Condominiums, Licensing Rules, Managers

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Jan-Martin LeBlanc

New Mining Act: A Detailed Review

In this article: - New Mining Act – Bill 43 - Exploration Phase - Procedure, Duty to Disclose and Reports - Mining Restrictions - Management of Mining Claims - Extraction Phase…more

Disclosure Requirements, Mineral Exploration, Mining, New Legislation, Penalties

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Charlene Lipchen

Canada Introduces New Legislation to Combat Counterfeit Products

On May 31, 2013, Bill C-56, the Combating Counterfeit Products Act (“CCPA”), received its second reading. The CCPA, if enacted, will provide trade-mark and copyright owners with powerful new tools against counterfeiters. It will…more

Canada, Copyright, Counterfeiting, Proposed Legislation, Trademarks

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Kevin MacNeill

New initiatives from the WSIB in 2013

The Workplace Safety and Insurance Board (“WSIB”) is in a state of flux, with many changes happening now and more on the horizon. In order to keep you up-to-date on the most recent workers’ compensation initiatives, this update…more

Contractors, Independent Contractors, Renovations, WSIA, WSIB

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Frederico Marques

The Upcoming Brazilian Mining Code: Preliminary Thoughts on the New Draft Released this Week

Earlier last week, the special commission of the Brazilian Congress released a substitutive project for the country’s proposed mining code (the “Revised Draft Mining Code”). The Revised Draft Mining Code has significant…more

Mining

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Cynthia Mason

Canada Introduces New Legislation to Combat Counterfeit Products

On May 31, 2013, Bill C-56, the Combating Counterfeit Products Act (“CCPA”), received its second reading. The CCPA, if enacted, will provide trade-mark and copyright owners with powerful new tools against counterfeiters. It will…more

Canada, Copyright, Counterfeiting, Proposed Legislation, Trademarks

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Daniel Mayer

New Year Construction Projects: Not Before A Clearance Certificate

In the New Year, condo corporations and their managers should pay close attention to new rules from the Workplace Safety and Insurance Board (“WSIB”) requiring them to obtain clearance certificates from the contractors they…more

Canada, Clearance, Condominiums, Contractors, WSIB

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Jean-François Mercadier

Merger Control in Africa

Created in 1994, the Common Market for Eastern and Southern Africa (the “COMESA”) is an organisation currently comprised of 19 African countries which aim at promoting regional integration in Eastern and Southern Africa (the…more

Acquisitions, Anti-Competitive, COMESA, Cross-Border, Notice Requirements

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Josh Milgrom

The Condominium Act, 2014? Update On Review And Recommendations

At only thirteen years young, the Condominium Act, 1998 (which became effective in 2001) is currently undergoing a full-scale review, led by Ontario’s Ministry of Consumer Services and Canada’s Public Policy Forum. The second of…more

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Jean-Jacques Essombè Moussio

The new security interests regime applicable in the Democratic Republic of Congo after its accession to OHADA1

By finally adhering to the OHADA Treaty and to the uniform acts promulgated thereunder (the “Uniform Acts”), the Democratic Republic of Congo (the “DRC”) has finally adopted a set of business laws which should create a more…more

Foreign Investment, OHADA Treaty, Securities

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Mark Newton

Pension Changes Proposed in Ontario Budget

On May 2, 2013, the Liberal government in Ontario released its proposed budget. While the NDP has not yet lent the proposed budget support in order to ensure its passage, the Heenan Blaikie Pensions, Benefits and Compensation…more

Canada, Federal Budget, Pensions

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David Palumbo

CSA Issues Guidance on Know-Your-Client, Know-Your-Product and Suitability Obligations

HIGHLIGHTS: - Establish policies and procedures for collection of KYC information, meaningful KYP and suitability assessment – provide adequate training to ensure understanding by representatives. - Take…more

Canada, Canadian Securities Administration, Compliance, Know Your Customers

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Anthony Penhale

OSC Proposes Rule Amendments Regarding Disclosure of Women on Boards and in Senior Management

On January 16, 2014, the Ontario Securities Commission (OSC) released proposed amendments to enhance the disclosure of boards’ gender diversity…more

Board of Directors, Canada, Diversity, Ontario Securities Commission

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Sara Perry

Understanding The Legal And Regulatory Considerations Of Concerns Of Creating Branded Content In Canada

This video entitled “Hello Madison and Vine, It’s Me, Bay Street: Understanding the Legal and Regulatory Considerations of Concerns of Creating Branded Content in Canada“ aired at the Canadian Marketing Association’s Content…more

Advertising, Brand, Canada, Content Marketing, Copyright

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Shawn Pulver

Does The Tarion Appeal Process Prevent A Condominium From Commencing A Civil Action?

We are often asked by condominium corporations whether an appeal of Tarion’s final decision letter will prevent them from commencing a separate civil action with respect to the same deficiencies…more

Appeals, Condominiums, Construction Defects, Home Warranties

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Andy Radhakant

Protecting Trade-marks in the New gTLDs

Trade-mark owners should act now to protect their trade-mark rights online. As early as April 2013, new top level domain names ("gTLDs") will be available. New domain names will no longer be limited to names ending in…more

Brand, gTLD, Trademark Clearinghouse, Trademarks

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Susan Rancourt

IPIC Consultation on Amendments to the Canadian Patent Act

In anticipation of government amendments to the Patent Act, likely after completion of a trade agreement with the European Union, the Intellectual Property Institute of Canada (IPIC) has begun an internal consultation with IPIC…more

Canada, IPIC, Patents, Proposed Amendments

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Sonia Regenbogen

Public Institutions, Procedural Fairness and Workplace Investigations

A recent case out of Quebec discusses the level of procedural fairness that may be owed during a workplace investigation for a public institution…more

Canada, Compliance, Harassment, Workplace Investigations

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Jason Rivait

Condominium Act Update On Stage Two Recommendations – Governance

The Stage 2 Solutions Report on the Condominium Act review (the “Report”) identifies five key areas for improvement relating to condo governance. The key areas and recommendations are summarized below..…more

Condominium Act, Condominiums

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Samuel M. Robinson

Foreign Issuers Take Note: The Expanding Reach of Ontario Securities Law

Yesterday, the Supreme Court of Canada refused to hear an appeal from an Ontario Court of Appeal decision permitting a secondary market liability securities class action to proceed in Ontario against a defendant whose shares are…more

Class Action, Foreign Investment, Ontario Securities Commission, Securities, Shareholder Litigation

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Nicolas Roche

Under the Umbrella: Quebec Superior Court Examines Excess Insurer’s Obligation to Defend

I. Introduction - On February 18, 2013, the Honourable Luc Lefebvre of the Quebec Superior Court rendered an interesting judgment regarding the excess insurer’s obligation to defend under an umbrella policy. Said…more

AIG, Canada, Duty to Defend, Excess Policies, Insurers

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Marie-Noël Rochon

Are You in a Conflict of Interest? Outside Business Activities Through the Lens of the Regulator

The Investment Industry Regulatory Organization of Canada (hereafter “IIROC”) published a Rules Notice on June 13, 2013, introducing the new Dealer Member Rule 43 which governs outside business activities and personal financial…more

Canada, Conflicts of Interest, Financial Actvities, New Regulations

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Karen Rogers

Second Phase of the CRM Project: Additional Disclosure of Charges and Performance Reports

The Canadian Securities Administrators (the “CSA”) published a notice on March 28, 2013 outlining the amendments made to National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations (“NI…more

Amended Regulation, Annual Reports, Canada, Canadian Securities Administration, Client Services

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Simon Ruel

Bill n°61: Solution to Amounts Paid Unjustly in the Construction Industry

After the revelations of corruption and collusion in the awarding of public contracts in the construction industry, most notably heard at the Charbonneau inquiry, the Government of Quebec announced its intention to table a bill…more

Canada, Construction Contracts, Corruption, Fraud, Reimbursements

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John Salmas

Indalex: Supreme Court of Canada Decision Released

The Supreme Court of Canada (“SCC”) recently released its much-anticipated decision in the Indalex Limited (“Indalex”) proceedings under the Companies’ Creditors Arrangement Act (the “CCAA Proceedings”). The decision is…more

CCAA, Constructive Trusts, Debtors-in-Possession, Defined Benefit Plans, Employer-Administrators

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Joseph Salmon

Condominium Lockers: Safety Concerns

As the baby boomer population ages and more individuals look to downsize, these individuals need to determine what to do with furnishings and possessions accumulated over the years. While their former four-bedroom home in the…more

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Marcelo König Sarkis

Canadian Intellectual Property Office Expands Patent Prosecution Highway to the United Kingdom

The Canadian Intellectual Property Office (CIPO) announced on January 31, 2012 that it entered into a Patent Prosecution Highway (PPH) Pilot Project with the United Kingdom Intellectual Property Office (UKIPO) for a period of…more

Patent Prosecution Highway, Patents

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Sophie Scemla

The Penalties Applicable to Legal Entities Convicted for Corruption under French Law - Are the Administrative Consequences the Only Deterrent?

Under French law, an act of corruption is exclusively subject to criminal liability; there is no administrative liability. Specific rules of administrative laws, however, which provide that a company convicted by a final…more

Administrative Fines, Bribery, Compliance, Corruption, Criminal Sanctions

See All Updates »

Samantha Seabrook

Public Institutions, Procedural Fairness and Workplace Investigations

A recent case out of Quebec discusses the level of procedural fairness that may be owed during a workplace investigation for a public institution…more

Canada, Compliance, Harassment, Workplace Investigations

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Michael Shedletsky

The New Generation Of Channel Surfing

With big media moguls rushing to have their share of the YouTube pie, it is worth examining the fundamental shift in the YouTube platform, prompting Peter Chernin, Time Warner Cable, and RTL Bertlesmann (the largest private…more

FCC, Google, YouTube

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Chantal Sylvestre

The Cultural Heritage Act, or How to Turn Something Old Into Something New!

Warning! Proceed with care: owners of heritage immovables are now subject to much more stringent rules including with respect to the preservation of the heritage value of their immovables. In the Fall of 2012, a new act was…more

Cultural Heritage Act, Tangible Property

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Bob Tarantino

Hernandez Gets Boo-urned In Federal Court – Statutory Damages For Copyright Infringement

As my colleague Monique Ashamalla pointed out over at our sister blog, IP Advocate, the Federal Court of Canada recently handed down a judgment of particular note to content owners: the court awarded $10,000,000 in statutory…more

Canada, Copyright, Copyright Infringement, Piracy

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Nicole Taylor-Smith

Are Live-In Caregivers Permitted In Single-Family Condo Units?

The Alberta Court recently considered whether having a live-in caregiver constituted a violation of a condominium’s By-laws that prohibited roomers and boarders and any use of a residential unit other than as a single-family…more

Bylaws, Canada, Caregivers, Condominiums

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Karen Tsang

Chinese New Year - ???? ????

With the Chinese New Year fast approaching, we have written this blog in simplified and traditional Chinese for our Chinese readers. The version below is in simplified Chinese…more

Condominiums, Decorations, Excessive Noise, Property Management Companies, Public Meeting Places

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Paola Turner

CSA Issues Guidance on Know-Your-Client, Know-Your-Product and Suitability Obligations

HIGHLIGHTS: - Establish policies and procedures for collection of KYC information, meaningful KYP and suitability assessment – provide adequate training to ensure understanding by representatives. - Take…more

Canada, Canadian Securities Administration, Compliance, Know Your Customers

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Sara-Ann Van Allen

Indalex: Supreme Court of Canada Decision Released

The Supreme Court of Canada (“SCC”) recently released its much-anticipated decision in the Indalex Limited (“Indalex”) proceedings under the Companies’ Creditors Arrangement Act (the “CCAA Proceedings”). The decision is…more

CCAA, Constructive Trusts, Debtors-in-Possession, Defined Benefit Plans, Employer-Administrators

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Evan Van Dyk

Pension Changes Proposed in Ontario Budget

On May 2, 2013, the Liberal government in Ontario released its proposed budget. While the NDP has not yet lent the proposed budget support in order to ensure its passage, the Heenan Blaikie Pensions, Benefits and Compensation…more

Canada, Federal Budget, Pensions

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Ben Wallwork

CIPO Issues New Guidance on Claims to Methods of Medical Use

The Canadian Patent Office recently released a new guidance document on “Examination Practice Respecting Medical Uses”. The guidance document, PN 2013-04, is directed to examiners, and relates to the consideration of claims…more

Canada, Canadian Intellectual Property Office, Medical Devices, Patent-Eligible Subject Matter, Patents

See All Updates »

Jeremy Warning

Corporate Criminal Conviction as Corporate Death Sentence? Court Says Companies Can Be Fined into Bankruptcy for Workplace Accidents

On September 4, 2013, the Court of Appeal for Ontario released its decision in the sentence appeal in R. v. Metron Construction Corporation (“Metron”). Government prosecutors had appealed against the C$200,000 fine Metron…more

Canada, Commercial Bankruptcy, Convictions, Corporate Criminal Fines, Criminal Negligence

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Kyler Wells

$16 Million Awarded for Breach of Bought Deal Engagement Letter by Dealer

Overview - On March 1, 2013, the Ontario Superior Court of Justice determined that Stifel Nicolaus Canada Inc. (formerly Thomas Weisel Partners Canada Inc.) breached its bought deal engagement letter with Stetson Oil &…more

Bought Deals, Engagement Letters, Financing

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Neil Wiener

Proposed New Prospectus Exemption for TSX Venture Exchange Companies (Except in Ontario)

On November 21, 2013, the securities commissions of each of the Canadian provinces (except Ontario and Newfoundland and Labrador) issued for comment a new prospectus exemption for companies listed on the TSX Venture Exchange. If…more

Canada, Exemptions, Prospectus, TSX Venture Exchange

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Keir Wilmut

Realtors Could Be Liable For Large Condominium Tax Bills

As we reported back in April, the CRA is increasingly challenging Canadians’ designation of their condominium unit as their principal residence. The distinction can result in a tax bill of tens of thousands of dollars…more

Canada, Condominiums, CRA, Liability, Real Estate Market

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Michael Woods

Bill C-60: A More Restrictive Approach to Foreign State-Owned Enterprise Investment in Canada

Introduction & Background - On December 7, 2012, the Government of Canada (the “Government”) approved two major foreign state-owned enterprise (“SOE”) acquisitions of Canadian oil sands businesses: the China National…more

Canada, China, Foreign Investment, Proposed Amendments, State-Owned Enterprises

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Sonia Yung

CSA Issues Guidance on Know-Your-Client, Know-Your-Product and Suitability Obligations

HIGHLIGHTS: - Establish policies and procedures for collection of KYC information, meaningful KYP and suitability assessment – provide adequate training to ensure understanding by representatives. - Take…more

Canada, Canadian Securities Administration, Compliance, Know Your Customers

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Stephen Zolf

"Consultation On Considerations Relating To Transfers, Divisions, And Subordinate Licensing Of Spectrum Licences" (Translation: How Many Competitive Players Do You Want In The Wireless Sector?)

An earlier post had discussed the issuance earlier this Spring of Industry Canada's new licensing framework for the Mobile Broadband Services (MBS) 700 MHz Band. As that post explained, the objective of the framework is to…more

Canada, Licenses, Mobile Broadband Services, Spectrum, Transfers

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