- Ontario, 2013
New York, 2009
Ian offers innovative tax solutions that enable his clients’ growth and success.
Ian advises clients on all areas of domestic and international income tax law, including mergers and acquisitions, reorganizations, financings, investment products and tax disputes. With a background in mathematics and technology, as well as extensive startup experience, Ian brings a rounded approach to the tax implications of new and emerging technologies. He is a trusted adviser to corporate entities, funds and financial institutions, which rely on his technical knowledge and commercial judgment.
Ian is a frequent speaker at national and international industry conferences. Before joining Davies, he practised for nearly a decade at a national law firm and at a prominent New York-based international law firm.
Acted for Sprott Inc. in the formation of Sprott Private Resource Streaming and Royalty Annex Fund, a US$310-million annex fund that invests alongside Sprott’s first streaming fund, which brings the combined total assets under management of Sprott Resource Streaming and Royalty Corp. in both funds to US$1.1 billion.
New York Life Insurance Company
Acted for New York Life Insurance Company in the Canadian private placement of C$1.05 billion of floating-rate and fixed-rate notes by New York Life Global Funding, a special purpose statutory trust organized under Delaware law, secured by a funding agreements issued by New York Life Insurance Company.
Premium Nickel Resources Limited
Acted for Premium Nickel Resources Ltd. (PNRL) in its C$34-million financing transactions with Cymbria Corporation and EdgePoint Investment Group Inc. The transactions comprised of an equity offering of units, a three year term loan and options to acquire 0.5% net smelter returns royalties on PNRL's Selebi and Selkirk mines.
Copper Mountain Mining Corporation
Acted for Copper Mountain Mining Corporation in its US$439-million all-share acquisition by Hudbay Minerals Inc. by way of a court approved plan of arrangement.
Metropolitan Life Insurance Company
Acted for Metropolitan Life Insurance Company, CIBC World Markets Inc., TD Securities Inc. BMO Nesbitt Burns Inc. and Scotia Capital Inc. in the Canadian private placement of C$1 billion of floating-rate and fixed-rate notes by Metropolitan Life Global Funding I, a special purpose statutory trust organized under Delaware law, secured by a funding agreements issued by Metropolitan Life Insurance Company.
Cornerstone Capital Resources Inc.
Acted for Cornerstone Capital Resources Inc. in its merger with SolGold plc under a court-approved plan of arrangement, consolidating ownership of the Cascabel project in northern Ecuador.
Valley Fiber Ltd.
Acted for Valley Fiber, a portfolio company of DIF Capital, in its acquisition of Commstream GigaLinks, an independent internet service provider in Manitoba.
Barrick Gold Corporation
Acted for Barrick Gold Corporation in the sale of a portfolio of 22 royalties to Maverix Metals for total cash consideration of up to US$60 million, and Nevada Gold Mines in the sale of a portfolio of three royalties to Gold Royalty Corp. for share consideration with a value of US$27.5 million.
Valley Fiber Ltd.
Acted for Valley Fiber, a portfolio company of DIF Capital, in its acquisition of Waterside Wireless, an independent internet service provider in Manitoba.
Acted for Points.com Inc., the global leader in powering loyalty commerce, in its sale by plan of arrangement to Plusgrade Parent L.P. in an all-cash transaction valuing Points at US$385 million.
Government of Canada Releases Package of Proposed Domestic and International Tax Legislation
Aug. 16, 2023 - The Department of Finance (Finance) released draft tax legislation for public consultation on August 4, 2023, with a stated focus on promoting tax fairness and a clean economy. The most significant item released is the draft of a major new statute, the Global Minimum Tax Act, spanning...
Two Percent Tax on Share Buybacks by Public Companies
Apr. 18, 2023 - As part of the 2023 federal budget, tabled on March 28, 2023, the government has introduced draft legislation to implement a new 2% tax on share buybacks that was first announced in November 2022 as part of the government’s Fall Economic Statement. This tax (referred to below as the “Buyback Tax”)...
Highlights of Canada’s Latest Legislative Tax Proposals
Aug. 23, 2022 - The Department of Finance recently released a package of materials containing potential changes to the Canadian tax system (Tax Proposals). The materials, released on August 9, 2022, include draft amendments to the Income Tax Act (Tax Act) to implement certain measures from the 2022...
Federal Budget 2022: Tax Highlights
Apr. 08, 2022 - On April 7, 2022 (Budget Day), the Honourable Chrystia Freeland, Deputy Prime Minister of Canada and Minister of Finance, delivered the Liberal Party’s federal budget (Budget 2022), the second budget since the start of the COVID-19 pandemic. As part of the Trudeau government’s plan to “grow our...
Ontario Bar Association, International Law Section, “Cross Border Digital Service Tax”; Webcast
Nov. 15, 2021
International Fiscal Association, A Mexico, US and Canada Approach, “Taxation on Blockchain”, Webcast
Aug. 25, 2021
Very-Short-Term Crypto Loans
May 15, 2021 - Canadian Tax Focus, Vol. 11, No. 2 (Canadian Tax Foundation)
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