Jan. 31, 2025 - First published by the Canadian Tax Foundation in (2024) 72:4 Canadian Tax Journal. Treaty Provides Unique Benefits To Canadians Migrating To The United States Canadians who emigrate to the United States or elsewhere face many decisions and considerations...
Announcement
Barrick Enters into a Gold and Silver Streaming Agreement with Royal Gold
Davies acted for Barrick Gold Corporation in connection with its gold and silver streaming agreement with RGLD Gold AG, a wholly owned subsidiary of Royal Gold, Inc., for production linked to Barrick’s 60% interest in the Pueblo Viejo mine. In return, Royal Gold agreed to make an upfront cash payment of $610 million plus continuing cash payments for gold and silver delivered under the agreement. Ongoing cash payments to Barrick were tied to prevailing spot prices rather than fixed in advance.
The Davies team on this transaction included Melanie Shishler, Richard Fridman, Robin Upshall and Scott Hyman (Corporate) and Geoffrey Turner (Taxation).
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Federal Court of Appeal Confirms CRA Can Collect Arrears Interest Despite Absence of a Tax Debt
Dec. 04, 2024 - The Federal Court of Appeal (FCA) recently dismissed the Bank of Nova Scotia’s (BNS) appeal and upheld the Canada Revenue Agency’s (CRA) practice of charging arrears interest on a non-existent tax debt where audit adjustments increase taxable income that is offset by the carryback of a loss...
