March 14, 2010
 
Montréal 

514.841.6409 (Direct Line)
514.841.6499 (Fax)

nboidman@dwpv.com

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Nathan Boidman
 
 
Nat Boidman is a partner in the Taxation practice. He specializes in international taxation, with a focus on advising on cross-border mergers and acquisitions, financings and other business arrangements and relationships, including joint ventures, partnerships and business trusts. Nat also provides counsel on disputes with Canada Revenue Agency stemming from cross-border tax matters, including transfer pricing and advises on individual international tax issues, including personal investment and migration matters.

Nat has 37 years of experience advising a diverse client base on the full range of international tax issues. In addition to his private client work, Nat has served as a special advisor to the Canadian government in the landmark case of Irving Oil and in other contexts.

Prior to his career in law, Nat was a partner in an accounting firm where he specialized in taxation.

Representative Work
  • Represented Potash Corporation of Saskatchewan Inc. since 1995 with respect to acquisitions running into US$ hundreds of millions and in some cases US$ billions in North America, South America and the Middle-East.
  • Represented Potash Corporation of Saskatchewan Inc. with respect to numerous financings, e.g., when it issued US$500 million notes due May 15, 2014 and US$500 million notes due May 15, 2019.
  • Represented GMAC LLC with respect to Canadian tax matters when it completed its late 2008 US$38.146 billion outstanding notes exchange and purchase offers and separate offers to exchange and purchase outstanding notes of Residential Capital, LLC.
  • Represented JP Morgan Partners, LLC and affiliates when they completed the sale from a control block of all of the shares of Telesystem International Wireless Inc. for an aggregate amount of approximately $830 million.
  • Represented Vitol Refining Group B.V. on Canadian tax matters and a particular securities matter regarding its sale of North Atlantic Refining Limited to Harvest Energy Trust in a transaction valued at $1.6 billion.
  • Represented Sentient Global Resources Fund Group in structuring investments in North America, the Far East and Australia, including a joint venture involving Ivernia in the Magellan lead mine in Western Australia, a transaction valued at US$55 million and, separately, with respect to a syndication providing a US$50 million senior secured credit facility for Ivernia.
  • Acted for Kimco Realty Corporation, a leading U.S.-based publicly-traded REIT in connection with a partnership with Sandalwood Management Canada Co. to acquire more than 1 million square feet of retail property comprised of six shopping centers in the Province of Québec, and with respect to several other Kimco acquisitions and investments in Canada.
  • Acted for Circuit City Stores, Inc. in its acquisition of InterTAN, Inc., the operator of Radio Shack stores in Canada, in a transaction valued at approximately US$286 million to create The Source by Circuit City.
  • Represented Euro-Pro Corporation and Omega Sewman Inc. in their US$250 million sale of Euro-Pro Operating LLC and related financing.
  • Represented Diamond Fields as well as one of its two major shareholders in its $4 billion sale to Inco.
  • Represented CIT Group in its $3 billion takeover of Newcourt.

Articles and Publications

Nat has written four books on taxation and published numerous articles in leading tax journals. Nat co-edits the feature, "Canada-U.S. Tax Practice" in Tax Management International Journal and has also written the Canadian chapters for several international tax publications and services, including "The Tax Treatment of Transfer Pricing", a loose leaf service published by the International Bureau of Fiscal Documentation (Amsterdam) and "Transfer Pricing: Foreign Rules and Practice Outside of Europe (Foreign Income Portfolios)" published by Tax Management, Washington.  Nat organized, for Tax Notes International, a special ongoing feature, involving 20 prominent and leading international tax lawyers, with regard to international M&A.

Teaching Engagements

Nat has lectured on the subject of taxation at the University of Sherbrooke's masters program in taxation and at McGill and Concordia Universities.

Speaking Engagements

Nat has spoken on the subject of transfer pricing to senior members of Canada Revenue Agency. He has participated in numerous speaking engagements for the Canadian Tax Foundation, Tax Executive Institute, the International Fiscal Association's ("IFA's") Annual Congresses, the Canadian Branch of the IFA, the American Bar Association, the International Bar Association, the Federal Bar Association and numerous commercial conference organizations over the last 30 years.


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