There was a period when fiduciary obligations were imposed or sought to be imposed in a somewhat reckless and sweeping fashion and without very specific tests. With the decisions of the Supreme Court of Canada in Frame v. Smith, and Lac minerals v. International Corona Resources, and the development of the governing principles by the Supreme Court and other courts in Canada, there is no considerably more precision to the imposition of fiduciary obligations and in particular their imposition in arm's length commercial relationships. Published in Corporate Litigation, Volume III, No. 4, 2000.