July 25, 2008
 
Mergers & Acquisitions Taxation
 
 
Sound tax planning is central to every successful M&A deal, from domestic private acquisitions to cross-border, public company transactions.  From our offices in Montreal, Toronto and New York, Davies tax lawyers consistently deliver sound, innovative, timely and comprehensive tax advice on a full range of domestic and international M&A transactions.

The following is a small sampling of recent transactions illustrating the scope of our practice:

  • Amcor Ltd. of Australia in its US $1.56 billion purchase of Schmalbach-Lubeca of Germany's international PET and White Cap closure business, including 58 subsidiaries across 26 countries;
    BCE Inc. in its $6.32 billion repurchase of SBC's 20% interest in Bell Canada;
  • Clarica Life Insurance Company in its $7.1 billion merger with Sun Life Financial Services of Canada Inc.;
  • Celestica Inc. in its acquisition from NEC Corporation of two advanced manufacturing facilities in Japan and the establishment of a 5-year outsourcing agreement anticipated to generate US $2.5 billion in revenue;
  • Acquisition of The Circle K Corporation by Alimentation Couche-Tard from ConocoPhillips Company ($1.06 billion) and the financing of the acquisition by the private placement of $223.6 million of subscription receipts, US$350 million of senior subordinated notes and US$620 million senior credit facilities;
  • Barrick Gold Corporation in its U.S. $2.25 billion acquisition of Homestake Mining Company, a NYSE listed company, by way of a Delaware share-for-share exchange;
    Hurricane Hydrocarbons in its successful take-over defence of a bid made by Central Asian Industrial Holdings.