On January 9, 2023, the US Supreme Court heard oral argument in the matter of In re Grand Jury, No. 21-1397, which asked the Court to determine whether “dual-purpose” communications involving both legal and business advice...more
Recently, we wrote a blog post about the Supreme Court entertaining arguments on the scope of the attorney-client privilege in the context of dual-purpose communications paraphrasing a question from Justice Kagan during the...more
In a per curiam opinion, the U.S. Supreme Court has dismissed the writ of certiorari granted in In re: Grand Jury, No. 21-1397, writing only that it was “improvidently granted.” The Court can dismiss any granted writ of...more
The Sixth Circuit Court of Appeals recently explored the limitations of Section 1692(f)(6) and held that a property preservation and maintenance company was not a debt collector for purposes of that section. The opinion...more
On February 12, 2020, the Federal Court of Appeal (FCA) in Canada v Alta Energy Luxembourg S.A.R.L., 2020 FCA 43 [Alta Lux] concluded that the Canada-Luxembourg tax treaty (Can-Lux Treaty) was not abused when a Luxembourg...more
On August 29, 2019, Canada completed its domestic ratification of the OECD-sponsored Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI). As noted in our...more
Tax-efficient holding structures commonly used by multinational enterprises and private equity firms investing in the Canadian resource sector could soon become subject to anti-treaty shopping measures contained in the...more
Persons or entities that engage third parties to collect consumer debts they acquired when the debts were in default, known as "passive debt buyers," are "debt collectors" subject to the Fair Debt Collection Practices Act...more
On February 4th, 2019, the Belgian government released a draft law ratifying the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the "Convention") and the...more
On October 17, 2018, the Bureau of Consumer Financial Protection (BCFP), formerly known as the CFPB, announced that it plans to issue a Notice of Proposed Rulemaking (NPRM) for the Fair Debt Collection Practices Act (FDCPA)...more