Christian Lachance and Benjamin Jarvis consider proposed amendments to the Wage Earner Protection Program Act under Bill C-39 that would restrict access to the Wage Earner Protection Program (WEPP) following reverse vesting order (RVO) transactions, potentially overturning the approach adopted in recent decisions by defining a “former employer” as the entity for which employees actually worked and limiting coverage to businesses that permanently cease operations, while addressing the implications for transaction structuring, employee claims and the allocation of wage liabilities among debtors, purchasers and lenders.

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