We were retained by counsel to assess the commercial nature of an agreement between CAE Inc. and the Canadian government In the context of an income tax dispute. CAE Inc. is a leading global manufacturer of flight simulators and related technologies servicing the aerospace, aircraft and defence industries.
Our analysis involved the assessment of the commercial terms of the arrangement including the interest rate, repayment terms, security and other key terms and conditions. Our analysis was required to assess whether the terms were commercial in nature and typical of an arm’s length market agreement. We provided an expert opinion and expert testimony at trial.