Respected by his clients for his practical, business-oriented advice, John has expertise in all aspects of domestic and international tax planning.
He works closely with leading private and public companies, as well as pension funds, sovereign wealth funds, private equity firms and Crown corporations, on corporate reorganizations, mergers and acquisitions, and corporate finance matters. He frequently consults on cross-border transactions, structuring non-resident investment into Canada and outbound investment by Canadian multinationals. John also advises high-net-worth individuals on a wide variety of taxation matters.
In addition to his tax planning practice, John represents taxpayers in tax audit matters and in disputes with the Canada Revenue Agency and provincial taxation authorities, and acts as counsel in tax litigation matters before the courts.
A frequent speaker at tax conferences and contributor to various tax publications, John is particularly well-regarded for his thought leadership on the tax and legal issues surrounding financial technology and the budding blockchain industry.
Acting as Canadian tax counsel for Nutrien Ltd. and its subsidiary, Potash Corporation of Saskatchewan Inc., in Nutrien's offer to exchange all outstanding publicly held notes of PotashCorp and Agrium Inc. for new notes to be issued by Nutrien.
Acted as co-counsel to Airbus SE, a European leader providing tanker, combat and transport aircraft ,as well as a global leader in aeronautic, space and related services, in its divestiture of Vector Aerospace Holding SAS to StandardAero Aviation Holdings, Inc.
International Petroleum Investment Company
Acted as Canadian tax counsel for International Petroleum Investment Company, an Abu Dhabi-based sovereign wealth fund, on its merger with Mubadala Development Company, creating the 14th largest state-owned investment fund in the world with $125-billion in combined total assets and businesses in over 30 countries.
Potash Corporation of Saskatchewan Inc.
Acted as Canadian tax counsel for Potash Corporation of Saskatchewan Inc. in its US$36-billion merger of equals with Agrium Inc. to create the world-class integrated global supplier of crop inputs, Nutrien Ltd. This deal was named 2017's Deal of the Year by Lexpert magazine and won the Mining Deal of the Year award at the 2017 Canadian Dealmakers Awards.
Acted for Oceanwide Inc., a Montréal based insurance software firm, in connection with the sale of its business to Insurity Inc., a provider of core insurance processing and data integration and analysis solutions, based in Hartford, Connecticut.
Silver Point Capital, L.P.
Acted successfully on behalf of a private investment fund in an action, before the Québec Superior Court, for annulment of its exchange of about $10 million worth of exchangeable debentures for common shares of a public issuer. The case involved obtaining prior approval from the Canada Revenue Agency and final judgment from the Superior Court in a short timeframe of about 60 days.
Vision 7 International ULC
Acted for Vision 7 International ULC, a fully integrated marketing communications company, whose two major brands include Canadian marketing communication agency leader Cossette and the international PR firm Citizen Relations, in connection with its acquisition by BlueFocus Communication Group Co., Ltd., the No. 1 integrated communication and marketing services group in China.
Deutsche Bank Securities Inc., RBC Capital Markets, LLC, CIBC World Markets Corp. and Imperial Capital, LLC
Acted as Canadian counsel for the initial purchasers, Deutsche Bank Securities Inc., RBC Capital Markets, LLC, CIBC World Markets Corp. and Imperial Capital, LLC, in a US$375-million private placement of senior secured notes due 2019 issued by Tembec Industries Inc., a wholly-owned subsidiary of Tembec Inc.
G.I. Sportz Inc.
Acted for G.I. Sportz Inc. in connection with the acquisition of Tippmann Sports, LLC, a leading manufacturer and distributor of markers and goggles for the paintball, airsoft and laser tag industries.
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 initiative....
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 rules...
Revenu Québec Responds to Ombudsperson
Mar. 01, 2016 - Originally published in Canadian Tax Highlights this article examines Revenu Québec’s 2015-16 Action Plan meant to address various issues encountered by taxpayers in their dealings with the provincial tax authority. Download this article.
Canadian Tax Highlights: Head of Revenu Québec Summoned
Oct. 29, 2015 - On September 17, 2015, the Québec ombudsman, Raymonde Saint-Germain, tabled in the National Assembly her 2014-15 annual report on Revenu Québec. This article outlines the problems identified in the ombudsman’s report and describes the press release that Québec’s finance minister, Carlos Leitão,...
Canadian Tax Highlights
Oct. 19, 2015 - Litigants must consider cost implications at every stage of litigation. Generally, a cost-benefit analysis is required at theoutset, at different stages in the litigation proceedings, andbefore and during settlement negotiation. In tax litigation, thecost-benefit analysis can be a fairly simple...
Rebooting Money: The Canadian Tax Treatment of Bitcoin and Other Cryptocurrencies
Oct. 09, 2015 - Bitcoin is widely regarded as the world’s first decentralized digital currency, or “cryptocurrency. ” Bitcoin, like many cryptocurrency systems, operates via a peer-to-peer network that is independent of any government, central authority, or bank. All functions, such as the issuance, or “mining,”...
Non-application of the anti-avoidance rule aimed at foreign affiliates
June 01, 2014 - On April 23, 2014, the Federal Court of Appeal rendered its long-awaited decision in Canada v. Lehigh Cement Limited (2014 FCA 103), in which it gave a strict interpretation of the anti-avoidance rule provided for in paragraph 95(6)(b) of the Income Tax Act, which applies when a...
Québec Enacts Voluntary Retirement Savings Plan Rules
Feb. 06, 2014 - In December 2013, Québec became one of the first provinces to legislate a type of a pooled registered pension plan (PRPP) further to an initiative in this regard announced by the federal and provincial governments in 2010. The Québec PRPP is called a “Voluntary Retirement Savings Plan” or VRSP;...
Unanimous Shareholder Agreements – Still a CCPC After All These Years
Sept. 30, 2013 - Tax Net Pro Mergers & Acquisitions Newsletter (Taxnet Pro)
Daishowa: Still No Tax Patrimony?
June 20, 2013 - On May 23, 2013, the Supreme Court of Canada in Daishowa-Marubeni International Ltd. (2013 SCC 29) concluded that a vendor of property used in carrying on a business (in this case, a timber business) need not include in proceeds of disposition an estimated amount for future obligations...