Clients turn to Brian for his sophisticated planning skills and creative solutions for their critical taxation matters – in Canada and abroad.
Brian advises across a broad range of tax law, with particular emphasis on mergers and acquisitions, international tax planning and transfer pricing. He also advises high-net-worth individuals and families on trust and estate matters. He is regularly consulted for his expertise in structuring complex, major transactions, including on the first tax-deferred conversion of a mutual fund corporation into a REIT in Canada.
Brian applies his judgment and technical sophistication to serve public and private sector clients across a wide range of sectors, including biotechnology.
He brings a unique perspective and understanding of tax issues to our clients’ matters. Before joining Davies, Brian was a senior tax policy officer in the Tax Legislation Division of the Department of Finance Canada and a senior rulings officer in the corporate reorganizations and international group of the Rulings Directorate of the Canada Revenue Agency.
New Look Vision Group Inc.
Acting for New Look Vision Group Inc. in its $800-million projected sale to NL1 AcquireCo Inc., an entity created by funds managed by FFL Partners, LLC, a San Francisco-based private equity firm, Caisse de dépôt et placement du Québec and the Dr. H. Doug Barnes Family.
Acted as Canadian counsel to Alstom S.A. in its EUR4.4-billion strategic acquisition of Bombardier Transportation.
Equinoxe Virtual Clinic Corp.
Acted for Equinoxe Virtual Clinic Corp., a leading Canadian virtual care provider, in the sale of all of its issued and outstanding shares to Right-Health Inc., a subsidiary of TELUS Corporation and the owner and operator of the Akira virtual care platform.
Hypertec Infrastructures Inc.
Acted as lead tax counsel for Hypertec Infrastructures Inc. in the sale of its data center and colocation services business to Vantage Data Centers, one of the world's leading hyperscale data center providers.
Canopy Growth Corporation
Acted for Canopy Growth Corporation in its acquisition of a majority stake in BioSteel Sports Nutrition Inc., a leading producer of sports nutrition products.
Honeywell Venture Capital LLC
Acted for Honeywell Venture Capital LLC, one of the lead investors in a $25-million series B funding round by Attabotics, a robotics supply chain company based in Calgary.
Vance Street Capital LLC
Acted for Vance Street Capital LLC, a Los Angeles-based private equity firm, and its portfolio company R.S.T Instruments in the acquisition of Measurand Group, a leading designer and manufacturer of geotechnical instrumentation based in Fredericton, New Brunswick.
Acted for a minority stockholder of a private company in a buyout of the majority stockholder of that company by way of a cross-border acquisition of all the assets of that company through both equity and debt financing from a private equity firm and an institutional lender.
JAM Industries Ltd.
Acted for the shareholders of JAM Industries Ltd. in the sale of its majority interest to DCC Technology Holdings Canada Inc., a subsidiary of DCC plc.
Mierins Automotive Group
Acted as tax counsel for Mierins Automotive Group in the sale of 10 automotive dealerships operating in Ottawa, Kingston and Brockville.
CRA’s Audit Powers Have Limits: Challenging Excessive Requests for Information
June 25, 2019 - In three recent decisions, the courts have curtailed the Canada Revenue Agency’s (CRA’s) broad interpretation of its audit powers and, in so doing, have armed taxpayers with the legal means to push back against excessive or unreasonable requests for information (RFIs) by the CRA. First, in...
The CRA Cannot Compel Oral Interviews During an Audit
Apr. 10, 2019 - In Minister of National Revenue v Cameco Corporation, the Federal Court of Appeal (FCA) dismissed the Minister of National Revenue’s appeal and held that the Canada Revenue Agency’s (CRA’s) audit powers under the Income Tax Act (ITA) do not extend to compelling taxpayers to be...
2019 Federal Budget: Tax Highlights
Mar. 19, 2019 - Budget 2019 is the last federal budget of the current Liberal government before the upcoming federal election in October 2019. Tax-related measures are intended to advance the government’s stated priority of creating a fair tax system. Proposals include changes to the employee stock option rules,...
2018 Federal Budget: Tax Highlights
Feb. 27, 2018 - As anticipated, today’s federal budget (Budget 2018) focuses on a few targeted areas, including the taxation of passive investments made by private corporations, and does not contain any measures in response to the enactment of tax reform in the United States or relating to the OECD BEPS...
Canadian and U.S. Tax Laws: A Review of 2016 and a Look Ahead to 2017
Jan. 13, 2017 - The year 2016 was eventful from a Canadian tax perspective, with the current Liberal government introducing its first federal budget and important judicial developments that included two decisions in tax cases by the Supreme Court of Canada. Conversely, while U.S. tax developments in 2016 were...
Repeal of the Eligible Capital Property Regime: A Final Window of Opportunity for Canadian Business Owners
Apr. 01, 2016 - As part of Canada’s Federal Budget that was presented on March 22, 2016, Finance Minister Bill Morneau announced the repeal, effective January 1, 2017, of the existing eligible capital property ( ECP ) tax regime and its merger into the existing depreciable capital property rules. While the new...
2016 Federal Budget: Tax Highlights
Mar. 22, 2016 - The new Liberal government ’ s first budget (Budget 2016) has been the subject of anticipation and speculation, much of it apprehensive. Unusually, Budget 2016 is noteworthy for what it does not contain. Budget 2016 does not introduce changes to increase the tax rate on employee stock option...
Canadian and U.S. Tax Laws: A Review of 2015 and a Look Ahead to 2016
Jan. 20, 2016 - Each year at this time, we offer a look back at some of the more significant business and international tax developments in Canada and the United States over the past year and a look ahead to possible Canadian and U.S. tax developments in the coming year. Canadian Tax Review and Outlook ...
Will Tax Treatment for Canadian Stock Options Change?
Oct. 29, 2015 - The newly elected Liberal government indicated in its election platform that it intends to increase taxes on employee stock option benefits by limiting Canadian resident employees from claiming the stock option deduction (i.e., the capital gains equivalent taxation) in respect of option benefits in...
2015 Federal Budget: Tax Highlights
Apr. 21, 2015 - As has been widely predicted, today’s federal budget (Budget 2015) delivered a handful of tax “ goodies ” in the lead-up to the coming election. It also includes a number of important proposed changes to the corporate tax rules. They are noteworthy, although not as extensive as the corporate tax...
Chambers Global: The World’s Leading Lawyers for Business—Tax
Chambers Canada: Canada’s Leading Lawyers for Business—Tax
Tax Directors Handbook—Tax
The Legal 500 Canada—Tax (Leading Individual)
The Lexpert/American Lawyer Guide to the Leading 500 Lawyers in Canada—Corporate Tax
Lexpert Special Edition: Finance and M&A
Lexpert Guide to US/Canada Cross-Border Lawyers in Canada—Tax
The Canadian Legal Lexpert Directory—Corporate Tax (Most Frequently Recommended); Estate and Personal Tax Planning: Estate and Tax Planning
The Best Lawyers in Canada—Tax Law; Trusts and Estates (Lawyer of the Year 2018, Montréal)
Who’s Who Legal: Canada—Corporate Tax; Who’s Who Legal: Corporate Tax—Advisory
Expert Guides—Transfer Pricing