The case of the day is Masillionis v. Silver Wheaton Corp. (C.D. Cal. 2018). The case was for securities fraud. Silver Wheaton was a Canadian corporation whose shares traded on the NYSE. Masillionis claimed that Silver Wheaton had failed to disclose to investors a risk that Canada’s tax authority could reassess its tax liability for profits earned by its Cayman Island subsidiary. Via letters rogatory, he sought discovery of legal opinions Silver Wheaton’s accountants and auditors had received from its lawyers.
Tagged: Canada, conflict of laws, privilege