There are many authorities where activities conducted
outside of the province have nevertheless been subject to provincial Securities legislation. See R. v. Jaasam,  1 W.W.R. 245
(Alta. Prov. Ct.) and Midland Doherty Ltd. v. Zonailo, 
B.C.J. No. 2305, 43 B.C.L.R. 138 (C.A.).
 The province has jurisdiction over the offence when there
is a “sufficient connection between Ontario and the impugned
activities”. See Gregory & Co. v. Quebec (Securities Commission),
 S.C.R. 584,  S.C.J. No. 38 and Crowe v. Ontario
Securities Commission (2011), 108 O.R. (3d) 410,  O.J. No.
5547 (Div. Ct.), where the court stated [at para. 32]:
Provincial securities legislation can also be applied to regulate corporations
or individuals within the province in order to protect investors outside the
province from unfair, improper or fraudulent activities. Where the Commis-
sion is regulating trades that have an extraprovincial character, the question
is not the location of the investors; rather, it is whether there is a sufficient
connection between Ontario and the impugned activities and the entities
involved to justify regulatory action by the Commission.
 What is the proper test to be applied to determine when
the province has jurisdiction over the offence?
Does the Libman test apply to provincial legislation?
 In The Interpretation of Legislation in Canada, by Pierre-
André Côté (Toronto: Carswell, 2011), the author makes the fol-
lowing comments, at pp. 203-204:
Problems resulting from attempts to situate the person, the property and
the transactions which fall within the ambit of the enactment. On the one
hand, the physical location of person or property, the place where a trans-
action takes place or where an event occurs, does not necessarily coincide
with the situs which the law ascribes. On the other hand, considerations
of international comity influence the characterization of the text’s territo-
. . . . .
A statute does not have an extraterritorial effect simply because it applies
to person, property or transactions physically situated outside the
enacting body’s jurisdiction. In the eyes of the law, it is the situs which is
A statute of a given State will be said to have an extraterritorial effect if it
governs persons, property, juridical acts or facts which do not have a “real
and important link” with that State. [footnoted to Libman]
 The “extraterritorial” reach of provincial securities legis-
lation was specifically considered by the World Stock Exchange
(Re), 2000 LNABASC 39, 9 ASCS 658: