Gregg’s business mindset and strong technical skills inform the creative tax solutions he develops for clients.
Gregg advises clients on a wide range of tax issues relating to mergers and acquisitions, cross-border transactions, partnerships and limited liability companies, and structured finance and securitization. He represents non-U.S. investors in private equity funds, as well as investors and developers in renewable energy projects. High-net-worth individuals turn to Gregg for personalized and innovative tax counsel for their businesses. He is regularly called upon to coordinate due diligence teams preparing U.S. tax disclosure for securitization transactions, including offerings of REMIC interests to U.S. and foreign investors.
Before joining Davies, Gregg practised law at leading New York firms, developing significant expertise in negotiating and documenting tax provisions in complex corporate transactions. His clients included American Securities, Onex Corporation and Citigroup, as well as Visa Inc., which he advised during its IPO and pre-IPO restructuring.
Gregg performs pro bono work for various non-profit organizations, including community organizations focusing on arts education and poverty reduction.
Acted for Fortis Inc. with concurrent offerings of common shares for aggregate proceeds of approximately $1.2 billion. The offerings included a $690-million bought deal in Canada and the U.S. using the multijurisdictional disclosure system, including the exercise by the underwriters of their over-allotment option, and a concurrent $500-million registered direct offering to an institutional investor. Each of the offerings was made pursuant to a prospectus supplement under Fortis' existing base shelf prospectus.
BMO Capital Markets
Acted as Canadian and U.S. counsel to BMO Capital Markets in an at-the-market equity offering by cannabis company Organigram Holdings Inc. in Canada and the United States under the multijurisdictional disclosure system.
Bank of Montreal
Acted for Bank of Montreal and a syndicate of lenders in the establishment of a $275-million revolving credit facility for Jamieson Laboratories Ltd. and its U.S. subsidiary.
Russel Metals Inc.
Acted for Russel Metals Inc. in its $160-million acquisition of City Pipe & Supply Corp., a Texas-based supplier of pipe, valves, and fittings to oil and gas companies in the United States.
Amcor Flexibles LLC
Acted for Amcor Flexibles LLC in the US$215-million sale of its three healthcare manufacturing facilities to Tekni-Plex, a globally-integrated company focused on developing and manufacturing products for a wide variety of end markets, including medical, pharmaceutical, food, beverage, personal care, household and industrial.
AirBoss of America Corp.
Acted for AirBoss of America Corp. to form a new defense business, AirBoss Defense Group, through the merger of its AirBoss Defense business and other operations in Acton Vale, Québec, with privately owned, U.S.-based Critical Solutions International, Inc., in a transaction valued at approximately US$132.7 million.
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.
International Imaging Materials, Inc.
Acted for International Imaging Materials, Inc., a leading developer and manufacturer of value-added consumable solutions for industrial and medical applications and a portfolio company of Altus Capital Partners, in its sale to ACON Investments, LLC.
Canadian Technical Tape Ltd.
Acted for Canadian Technical Tape Ltd. in connection with its acquisition by Intertape Polymer Group Inc., a TSX-listed company.
Acted for 500 Startups in the formation of its first Canadian venture capital seed fund.
IRS Issues New Final and Proposed Regulations Under the U.S. Base Erosion and Anti-Abuse Tax
Dec. 10, 2019 - Summary The IRS released final and proposed regulations providing further guidance and addressing certain open issues under the base erosion and anti-abuse tax (BEAT). The final regulations, based partly on the IRS’s response to comments received, clarify previously proposed regulations, such as...
Qualified Opportunity Zones and the Opportunity for Foreign Investors, co-author
July 30, 2019 - International Tax Journal, Vol. 45. No. 4 (Wolters Kluwer)
U.S. Issues Taxpayer-Favourable Regulations Under GILTI and Subpart F Regimes
July 03, 2019 - The U.S. Treasury Department and the IRS have issued guidance relating to the new tax on the “global intangible low-taxed income” (GILTI) of a “controlled foreign corporation” (CFC). Generally, GILTI is the portion of a CFC’s earnings that exceeds a specified return on the CFC’s foreign assets. ...
IRS Proposes Regulations That Would Liberally Apply Exemption from FIRPTA to Qualified Foreign Pension Funds
June 07, 2019 - The IRS recently released long-awaited proposed regulations to implement an exemption from U.S. federal taxes on the disposition of interests in U.S. real estate by certain foreign pension funds known as “qualified foreign pension funds” (QFPFs). BackgroundUnder the Foreign Investment in Real...
IFA International Tax Conference 2019, “Select U.S. Legislative & Case Law Developments”; Montréal, QC
May 15, 2019
IRS Proposes New Rules for Withholding on Interest Transfers in Certain Partnerships
May 13, 2019 - The landmark U.S. tax reform legislation that was enacted at the end of 2017 contained a new federal income tax on gain realized by a foreign seller on the transfer of an interest in a partnership that is engaged in a U.S. trade or business. This measure reversed a court decision that had...
Canadian and U.S. Tax Laws: A Review of 2018 and a Look Ahead to 2019
Jan. 31, 2019 - In our annual Tax Review and Outlook report, we look back at significant developments in the Canadian and U.S. tax landscapes in 2018 and offer our predictions on what to expect in 2019. Key Canadian Developments in 2018 Budget 2018 scaled back controversial initiative on taxation of passive...
U.S. Tax Laws: A Review of 2018 and a Look Ahead to 2019
Jan. 31, 2019 - Review of U.S. Tax Developments in 2018U.S. taxpayers will remember 2018 as the year spent coming to terms with the tax reform legislation enacted at the end of 2017, known as the Tax Cuts and Jobs Act (TCJA). The TCJA included a surprisingly large number of new tax rules that have...
U.S. Proposed Regulations Target Hybrid Structures and Instruments Retroactively
Jan. 03, 2019 - The United States was initially reluctant to adopt the recommendations of the base erosion and profit shifting (BEPS) initiative spearheaded by the OECD and the G20 group of nations. However, the major tax reform legislation known as the Tax Cuts and Jobs Act includes several provisions...
Selected US Tax Developments, co-author
Dec. 15, 2018 - Canadian Tax Journal, Vol. 66, Issue 4 (Canadian Tax Foundation)
Read more on Selected US Tax Developments.