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Arm’s Length Transaction or Not? Canada v Loblaw Financial Holdings Inc.

Introduction In Canada v Loblaw Financial Holdings Inc., 2021 SCC 51 [“Loblaw”], the Supreme Court of Canada (“SCC”) examines “one of the most complex tax schemes, with hundreds of definitions, rules, and exceptions that shift regularly” (Loblaw, para 28). The vital, yet straightforward, question being decided in the appeal is “does a parent corporation conduct […]