John J. Lennard

Partner

John J. Lennard

John J. Lennard

Partner

Expertise
Bar Admissions
  • Québec, 2011

Clients turn to John for his practical and business-oriented advice on 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.

John J. Lennard

Partner

Clients turn to John for his practical and business-oriented advice on 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.

Aebi Schmidt Holding AG

Acted for Aebi Schmidt Holding AG in its acquisition of Équipements Lourds Papineau Inc., a leading manufacturer of automotive equipment and attachments for snow removal and road maintenance.

Triage Technologies Inc.

Advising Triage Technologies Inc., a Toronto-based and AI-powered digital health company, with its business structure, commercial agreements and equity raise.

Vista Equity Partners

Acted for Vista Equity Partners in its joint investment with TA Associates in Aptean, a leading global provider of mission-critical, industry-specific enterprise software solutions.

BELLUS Health Inc.

Acted as counsel to BELLUS Health Inc. in its US$70-million initial public offering in the United States.

Cominar Real Estate Investment Trust

Acted for Cominar Real Estate Investment Trust in the public offering of its 4.5% Series 11 senior unsecured debentures due May 15, 2024, for the principal amount of $200 million.

Vista Equity Partners III LLC

Acted for Vista Equity Partners in the carve-out sale of the vertical business applications group of its Aptean portfolio companies to a subsidiary of ESW Capital, LLC.

Vista Equity Partners III, LLC

Acted for Vista Equity Partners in the carve-out by its portfolio company, Aptean, Inc., of its public sector and healthcare business and the merger of that business with Superion, LLC, and TriTech Software Systems Inc. to form one of the largest conglomerates focused specifically on state and local governments in North America.

tZERO.com, subsidiary of Overstock.com

Acting as Canadian counsel for tZERO.com, the financial technology subsidiary of Overstock.com, in its USD$250-million offering of security tokens using blockchain technology by way of a Simple Agreement for Future Equity (SAFE).

Nutrien Ltd.

Acted 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.

Airbus SE

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.

Neovia Probiotics Inc.

Acted for Neovia Probiotics Inc., an indirect subsidiary of a leading French agricultural cooperative group, in its acquisition (by way of a plan of arrangement) of Epicore BioNetworks Inc., a TSXV-listed company specializing in the sale of environmental biological products and specialty feeds.

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.

Waterton Global Resource Management

Acted as Canadian tax counsel to Waterton Global Resource Management in connection with the launch of its third private equity fund, Waterton Parallel Fund, with total capital commitments of US$725 million.

Oceanwide Inc.

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.

Paladin Labs Inc.

Acted for Paladin Labs Inc. in connection with its acquisition by Endo Health Solutions Inc. in a stock and cash transaction valued at approximately $3 billion.

Bulletin

Disclosure Rules for Nominee Contracts Come into Force in Québec

Oct. 02, 2020 - Bill 42, An Act to give effect to fiscal measures announced in the Budget Speech delivered on 21 March 2019 and to various other measures was assented to on September 24, 2020, bringing into force the new rules respecting the disclosure of nominee contracts to Revenu Québec (RQ ). The...

Bulletin

Deadlines Under Federal Legislation Temporarily Extended Due to COVID-19

Sept. 24, 2020 - Introduction Parliament passed on July 27, 2020, the Time Limits and Other Periods Act (COVID-19) (Time Limits Act), which we summarized in a previous bulletin. Briefly, the Time Limits Act automatically suspends statutory time limits for federal civil proceedings for six months and...

Bulletin

Canadian Government’s Proposed Extension of Time Limits Due to COVID-19

May 27, 2020 - As part of the federal government’s response to the COVID-19 pandemic, the Department of Finance recently published a draft legislative proposal, the Time Limits and Other Periods Act (COVID-19) (Proposal), that, if implemented, would provide for an automatic six-month suspension of time...

Bulletin

Canadian Tax Laws: A Review of 2019 and a Look Ahead to 2020

Jan. 30, 2020 - Each year at this time we look back at some of the more significant income tax developments in Canada affecting domestic and international business over the past year and look ahead to possible Canadian tax developments in the coming year. Review of Canadian Tax Developments in 2019 Tax...

Bulletin

Extended Deadline for Québec Nominee Agreement Disclosure

Aug. 22, 2019 - As outlined in our e-communications of May 21, 2019, and August 12, 2019, Québec’s Ministry of Finance has introduced new rules regarding the disclosure of nominee agreements. The new disclosure requirement is relevant to nominee agreements involving one or more parties that are subject to Québec...

Article

Interpreting the Expression “Arrangement or Transaction” in the Principal Purpose Test of the MLI, co-author

June 01, 2019 - International Tax Newsletter, No. 106 (Wolters Kluwer)
Download this article.

Bulletin

Proposed Amendments to the GST/HST Treatment of Cryptocurrencies

May 27, 2019 - The Department of Finance (Canada) (Finance Canada) has released, for public comment, draft legislative proposals (Draft Proposals) to amend the Excise Tax Act (ETA) in order to address certain issues regarding the treatment of virtual currencies for the purposes of the goods and services...

Bulletin

Québec Announces New and Expanded Measures to Combat Aggressive Tax Planning

May 21, 2019 - Québec’s Ministry of Finance (Finances Québec) recently published Information Bulletin 2019-5 (Bulletin) setting out new and significantly expanded measures to combat aggressive tax planning. These measures (published on May 17, 2019 and alluded to in the Québec budget of March 21, 2019) are the...

Bulletin

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,...

Bulletin

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...

Bar Admissions

Québec, 2011

Education

Chartered Professional Accountants of Canada, In-Depth Tax Course, Levels I, II & III
McGill University, BCL/LLB (Highest Standing in Corporate Taxation), 2011
Laurentian University, BComm (Hons), 2007

Professional Affiliations

Association de planification fiscale et financière
Canadian Bar Association
Canadian Tax Foundation, Montréal Young Practitioners Group

Community Involvement

Canadian Bar Association, Sexual Orientation and Gender Identity Committee, Québec Steering Committee

Clients turn to John for his practical and business-oriented advice on 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.

Aebi Schmidt Holding AG

Acted for Aebi Schmidt Holding AG in its acquisition of Équipements Lourds Papineau Inc., a leading manufacturer of automotive equipment and attachments for snow removal and road maintenance.

Triage Technologies Inc.

Advising Triage Technologies Inc., a Toronto-based and AI-powered digital health company, with its business structure, commercial agreements and equity raise.

Vista Equity Partners

Acted for Vista Equity Partners in its joint investment with TA Associates in Aptean, a leading global provider of mission-critical, industry-specific enterprise software solutions.

BELLUS Health Inc.

Acted as counsel to BELLUS Health Inc. in its US$70-million initial public offering in the United States.

Cominar Real Estate Investment Trust

Acted for Cominar Real Estate Investment Trust in the public offering of its 4.5% Series 11 senior unsecured debentures due May 15, 2024, for the principal amount of $200 million.

Vista Equity Partners III LLC

Acted for Vista Equity Partners in the carve-out sale of the vertical business applications group of its Aptean portfolio companies to a subsidiary of ESW Capital, LLC.

Vista Equity Partners III, LLC

Acted for Vista Equity Partners in the carve-out by its portfolio company, Aptean, Inc., of its public sector and healthcare business and the merger of that business with Superion, LLC, and TriTech Software Systems Inc. to form one of the largest conglomerates focused specifically on state and local governments in North America.

tZERO.com, subsidiary of Overstock.com

Acting as Canadian counsel for tZERO.com, the financial technology subsidiary of Overstock.com, in its USD$250-million offering of security tokens using blockchain technology by way of a Simple Agreement for Future Equity (SAFE).

Nutrien Ltd.

Acted 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.

Airbus SE

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.

Neovia Probiotics Inc.

Acted for Neovia Probiotics Inc., an indirect subsidiary of a leading French agricultural cooperative group, in its acquisition (by way of a plan of arrangement) of Epicore BioNetworks Inc., a TSXV-listed company specializing in the sale of environmental biological products and specialty feeds.

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.

Waterton Global Resource Management

Acted as Canadian tax counsel to Waterton Global Resource Management in connection with the launch of its third private equity fund, Waterton Parallel Fund, with total capital commitments of US$725 million.

Oceanwide Inc.

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.

Paladin Labs Inc.

Acted for Paladin Labs Inc. in connection with its acquisition by Endo Health Solutions Inc. in a stock and cash transaction valued at approximately $3 billion.

Bulletin

Disclosure Rules for Nominee Contracts Come into Force in Québec

Oct. 02, 2020 - Bill 42, An Act to give effect to fiscal measures announced in the Budget Speech delivered on 21 March 2019 and to various other measures was assented to on September 24, 2020, bringing into force the new rules respecting the disclosure of nominee contracts to Revenu Québec (RQ ). The...

Bulletin

Deadlines Under Federal Legislation Temporarily Extended Due to COVID-19

Sept. 24, 2020 - Introduction Parliament passed on July 27, 2020, the Time Limits and Other Periods Act (COVID-19) (Time Limits Act), which we summarized in a previous bulletin. Briefly, the Time Limits Act automatically suspends statutory time limits for federal civil proceedings for six months and...

Bulletin

Canadian Government’s Proposed Extension of Time Limits Due to COVID-19

May 27, 2020 - As part of the federal government’s response to the COVID-19 pandemic, the Department of Finance recently published a draft legislative proposal, the Time Limits and Other Periods Act (COVID-19) (Proposal), that, if implemented, would provide for an automatic six-month suspension of time...

Bulletin

Canadian Tax Laws: A Review of 2019 and a Look Ahead to 2020

Jan. 30, 2020 - Each year at this time we look back at some of the more significant income tax developments in Canada affecting domestic and international business over the past year and look ahead to possible Canadian tax developments in the coming year. Review of Canadian Tax Developments in 2019 Tax...

Bulletin

Extended Deadline for Québec Nominee Agreement Disclosure

Aug. 22, 2019 - As outlined in our e-communications of May 21, 2019, and August 12, 2019, Québec’s Ministry of Finance has introduced new rules regarding the disclosure of nominee agreements. The new disclosure requirement is relevant to nominee agreements involving one or more parties that are subject to Québec...

Article

Interpreting the Expression “Arrangement or Transaction” in the Principal Purpose Test of the MLI, co-author

June 01, 2019 - International Tax Newsletter, No. 106 (Wolters Kluwer)
Download this article.

Bulletin

Proposed Amendments to the GST/HST Treatment of Cryptocurrencies

May 27, 2019 - The Department of Finance (Canada) (Finance Canada) has released, for public comment, draft legislative proposals (Draft Proposals) to amend the Excise Tax Act (ETA) in order to address certain issues regarding the treatment of virtual currencies for the purposes of the goods and services...

Bulletin

Québec Announces New and Expanded Measures to Combat Aggressive Tax Planning

May 21, 2019 - Québec’s Ministry of Finance (Finances Québec) recently published Information Bulletin 2019-5 (Bulletin) setting out new and significantly expanded measures to combat aggressive tax planning. These measures (published on May 17, 2019 and alluded to in the Québec budget of March 21, 2019) are the...

Bulletin

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,...

Bulletin

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...

Bar Admissions

Québec, 2011

Education

Chartered Professional Accountants of Canada, In-Depth Tax Course, Levels I, II & III
McGill University, BCL/LLB (Highest Standing in Corporate Taxation), 2011
Laurentian University, BComm (Hons), 2007

Professional Affiliations

Association de planification fiscale et financière
Canadian Bar Association
Canadian Tax Foundation, Montréal Young Practitioners Group

Community Involvement

Canadian Bar Association, Sexual Orientation and Gender Identity Committee, Québec Steering Committee