Senior Counsel
“He really understands the industry and technical aspects of what we’re trying to achieve.”
Client – Chambers Global 2016
Geoff advises clients on all aspects of domestic and cross-border tax planning, mergers and acquisitions, corporate reorganizations and corporate finance matters. Clients appreciate his thoughtful analysis of complex situations.
Over more than 25 years, Geoff has developed particular expertise in advising Canada-based multinationals on international tax matters. They rely on his deep understanding of foreign affiliate tax rules to guide them in their critical transactions. He regularly advises Canadian mining companies with foreign mining operations.
Geoff teaches Taxation of Business Enterprises at Osgoode Hall Law School and International Tax Law at Western University.
Senior Counsel
“He really understands the industry and technical aspects of what we’re trying to achieve.”
Client – Chambers Global 2016
Geoff advises clients on all aspects of domestic and cross-border tax planning, mergers and acquisitions, corporate reorganizations and corporate finance matters. Clients appreciate his thoughtful analysis of complex situations.
Over more than 25 years, Geoff has developed particular expertise in advising Canada-based multinationals on international tax matters. They rely on his deep understanding of foreign affiliate tax rules to guide them in their critical transactions. He regularly advises Canadian mining companies with foreign mining operations.
Geoff teaches Taxation of Business Enterprises at Osgoode Hall Law School and International Tax Law at Western University.
Barrick Gold Corporation
Acted for Barrick Gold Corporation in its US$428-million acquisition of all of the outstanding shares of Acacia Mining plc (Acacia) not already owned by Barrick by way of a court-sanctioned scheme of arrangement under Part 26 of the Companies Act 2006 (United Kingdom).
Barrick Gold Corporation
Acted for Barrick Gold Corporation in its historic joint venture with Newmont Goldcorp Corporation, which combined their respective mining operations, assets, reserves and talent in Nevada to create the world's largest gold complex.
Barrick Gold Corporation
Acted for Barrick Gold Corporation in its unsolicited proposal to the Newmont Goldcorp Corporation (Newmont) Board of Directors to merge with Newmont in an all share transaction to combine the world's two largest gold companies. Under the proposal, Barrick shareholders would own approximately 55.9 percent and Newmont shareholders would own approximately 44.1 percent of the combined company with an approximate market capitalization of US$42 billion.
Barrick Gold Corporation
Acted for Barrick Gold Corporation in its recommended US$18.3-billion share-for-share merger with Randgold Resources Limited. This complex and multijurisdictional transaction created an industry-leading gold company with the greatest concentration of tier one gold assets in the industry and a diversified asset portfolio positioned for growth.
Barrick Gold Corporation
Acted for Barrick Gold Corporation in connection with a transaction with Shandong Gold that included the sale of a 50% interest in the Veladero gold mine for US$960 million; the negotiation of a 50/50 joint venture arrangement in respect of the Veladero gold mine; the negotiation of a strategic cooperation agreement to explore the joint development of the Pascua-Lama deposit located along the Chilean-Argentinean border; and the evaluation of additional investment opportunities on the highly prospective El Indio Gold Belt on the border of Argentina and Chile.
Barrick Gold Corporation
Acted for Barrick Gold Corporation in connection with its sale of a 25% stake in the Cerro Casale Project to Goldcorp, and the negotiation of a 50/50 regional joint venture over the Cerro Casale, Quebrada Seca and Caspiche projects in Chile's Maricunga district. This highly complex and multi-faceted transaction involved the acquisition by Goldcorp of Kinross' entire 25% interest in the Cerro Casale Project and a 25% interest in the project from Barrick, whose holding in the project will fall from 75% to 50%. Upon closing of the transaction, the joint venture was established.
Barrick Gold Corporation
Acted for Barrick Gold Corporation in connection with an earn-in agreement with Alicanto Minerals of Australia. Under the terms of the Earn-In, Barrick will be able to earn a 65% interest in the Arakaka project in northwest Guyana by meeting total funding requirements of US$10 million over 4 years.
New Gold Inc.
Acted for New Gold Inc. in connection with the sale of its 30% interest in the El Morro copper-gold project in Chile to Goldcorp Inc. in exchange for a $90-million cash payment, a 4% gold stream on life-of-project gold production from the El Morro property and cancellation of a $93-million carried funding loan. In conjunction with the transaction, Goldcorp and Teck Resources Limited announced that they plan to combine their respective El Morro and Relincho properties into a 50/50 joint venture with the interim name of Project Corridor.
Barrick Gold Corporation
Acted for Barrick Gold Corporation in connection with its US$610-million gold and silver streaming agreement with Royal Gold Inc. for production linked to Barrick's 60 percent interest in the Pueblo Viejo mine.
Barrick Gold Corporation
Acted for Barrick Gold Corporation in connection with its $1.005-billion sale of a 50% interest in the Zaldívar copper mine in Chile to Chile-based Antofagasta Plc and related joint venture arrangements.
Upstream Loans and Dispositions of Foreign Affiliate Shares
Jan. 19, 2016 - This article summarizes the upstream loan rules, and explores the impact of the upstream loan rules in several situations involving dispositions of the shares of the creditor foreign affiliate. In general, under the current rules anomalous results can be avoided with certainty only by causing the...
ACB Adjustments for Foreign Affiliate Shares Held Through Partnerships
Nov. 05, 2015 - Originally published in the CCH International Tax Newsletter, this article first briefly compares the treatment of dividends and capital distributions paid by foreign affiliates directly to a Canadian corporate shareholder and those indirectly paid through a partnership holding structure....
Metal Streams in Foreign Affiliates
Nov. 05, 2015 - Originally published in the CCH International Tax Newsletter, this article considers the principal features of the typical metal stream transaction that are relevant from a tax perspective. The focus is on the common situation of a Canadian parent company owning a non-Canadian mining...
Canadian International Tax Rules: June 2014 Foreign Affiliate Tax Elections
Apr. 29, 2014 - June 2014 is the deadline for Canadian corporations to make potentially important tax elections relating to recently enacted changes to the foreign affiliate reorganization rules in the Income Tax Act (Canada) which are retroactive to December 20, 2002. Companies whose foreign affiliates...
Apr. 02, 2014 - This article examines the new foreign affiliate reorganization provisions and key elections affecting Canadian corporations with foreign affiliates. It may now be possible for taxpayers to clarify, proactively confirm, or even change the intended tax consequences of historic transactions that...
USA Branch of the International Fiscal Association, annual conference, “Tax Developments and Tax Planning in Foreign Jurisdictions”; New York, NY
Feb. 28, 2013
The Best Lawyers in Canada—Tax Law
Who’s Who Legal: Canada—Corporate Tax
Ontario, 1993
Osgoode Hall Law School, LLM (Tax), 2005
University of Toronto, LLB (Honours), 1991
Queen’s University, BA (Economics) (Honours, Gold Medallist), 1988
Canadian Tax Foundation
Geoff teaches Taxation of Business Enterprises at Osgoode Hall Law School and International Tax Law at Western University. He has previously taught the tax component of the Advanced Mergers and Acquisitions Workshop and the International Tax Law course at Osgoode Hall Law School. He also previously co-taught the International Tax Law course at Western University, for which he was twice awarded the Students’ Council teaching award of excellence.
