John M. Ulmer

Partner

John M. Ulmer

John M. Ulmer

Partner

Expertise
Bar Admissions
  • Ontario, 1980

“The best tax lawyer I have worked with – he gets the best results.”
Chambers Global 2016

John advises on tax aspects of domestic and international business ventures for significant public and private companies in Canada, the U.S. and Europe, with a focus on the real estate industry. He is lead adviser to a number of Canadian-based multinational groups on the tax structuring of their global investments.

Clients value John for his extensive domestic and international tax knowledge, with one client saying John’s advice is “brilliant.” They appreciate that he takes on complex tax issues but can “discuss them in an intelligent yet simple way.” (Chambers Global 2016)

Canadian public and private real estate companies, REITs, and funds and other multinationals rely on John’s judgment. Known for his creativity, he is a pioneer in the establishment of cross-border REITs. He frequently advises international funds and corporations on investing in Canada.

John M. Ulmer

Partner

“The best tax lawyer I have worked with – he gets the best results.”
Chambers Global 2016

John advises on tax aspects of domestic and international business ventures for significant public and private companies in Canada, the U.S. and Europe, with a focus on the real estate industry. He is lead adviser to a number of Canadian-based multinational groups on the tax structuring of their global investments.

Clients value John for his extensive domestic and international tax knowledge, with one client saying John’s advice is “brilliant.” They appreciate that he takes on complex tax issues but can “discuss them in an intelligent yet simple way.” (Chambers Global 2016)

Canadian public and private real estate companies, REITs, and funds and other multinationals rely on John’s judgment. Known for his creativity, he is a pioneer in the establishment of cross-border REITs. He frequently advises international funds and corporations on investing in Canada.

The Blackstone Group Inc.

Acting for real estate funds managed by The Blackstone Group Inc. and their affiliates in Blackstone's $6.2-billion all-cash acquisition of Dream Global Real Estate Investment Trust and the separation of its external asset manager, Dream Asset Management.

Graywood Group

Acting for the Graywood Group with the acquisition and development of Fish Creek Exchange in Calgary, Alberta, which is a new community consisting of mid-rise mixed-use buildings and townhomes.

Graywood Group

Acting for the Graywood Group on the formation of a 50/50 joint venture for the development of a 47-storey condominium tower to be located at the corner of Peter and Adelaide in Toronto, Ontario, which will contain 695 residences and ground level retail.

Granite REIT

Acted as tax counsel to Granite REIT in its sale of a real estate portfolio in the United States and Canada for $400 million.

RioCan Real Estate Investment Trust

Acted for RioCan Real Estate Investment Trust on Canadian and US tax matters in connection with the US$1.9-billion sale of its portfolio of 49 shopping centres, located in the Northeastern U.S. and Texas, to Blackstone Real Estate Partners.

Fortress Investment Group, LLC and Holiday Retirement

Acted for Fortress Investment Group, LLC and Holiday Retirement in connection with the sale of 29 Canadian senior living communities to Ventas, Inc.

Spear Street Capital, LLC

Acted for Spear Street Capital, LLC in connection with its $305-million purchase of the majority of BlackBerry Limited's real estate holdings in Canada, including its global headquarters in Waterloo, Ontario. BlackBerry sold more than 3 million square feet of space as well as vacant lands, and leased back a portion of the space.

IPC Jerusalem Ltd.

Acted for IPC Jerusalem Ltd. in connection with the development of The Waldorf Astoria Jerusalem Hotel, a new five-star hotel in Jerusalem.

Air Canada

Acted as Canadian tax counsel for Air Canada in structuring the first Canadian Enhanced Equipment Trust Certificate (EETC) financing, permitting Air Canada to efficiently finance the acquisition of aircraft valued at over $900 million.

CIBC World Markets and RBC Dominion Securities

Acted in Canada and the U.S. for a syndicate of underwriters led by CIBC World Markets and RBC Dominion Securities in connection with the $114 million initial public offering of WPT Industrial REIT, Canada's only REIT focused exclusively on the U.S. industrial real estate sector.

BMO Nesbitt Burns Inc. and CIBC World Markets Inc.

Acted for a syndicate of underwriters led by BMO Nesbitt Burns Inc. and CIBC World Markets Inc. in connection with the $228-million initial public offering of Milestone Apartments Real Estate Investment Trust, the first IPO in the world of a qualifying U.S. REIT by a non-U.S. entity.

Granite Real Estate Inc.

Acted as Canadian and U.S. tax counsel to Granite Real Estate Inc. in its conversion under a plan of arrangement to an international stapled-unit REIT with an initial (NYSE/TSX) market capitalization of $1.8 billion. Granite REIT was the first REIT to qualify as a REIT for Canadian income tax purposes while holding both a Canadian and international portfolio; and also the first to achieve flow-through treatment for its U.S. portfolio by electing to be a partnership for U.S. purposes and utilizing a U.S. private REIT.

Article

Update on REITs and Structuring Public Vehicles for Investment in Canadian and Foreign Real Estate

Dec. 31, 2014 - Report of Proceedings of Sixty-fifth Tax Conference, 2013 Tax Conference Report (Canadian Tax Foundation)

Speaking Engagement

Canadian Tax Foundation, 2013 annual conference, “Update on REITs and Structuring Public Vehicles for Investment in Canadian and Foreign Real Estate”

Jan. 01, 2013

Speaking Engagement

OECD and the Italian Council of Ministers, Milan seminar, “Capital Gains on Shares Under Reorganizations”

Jan. 01, 2012

Chambers Global: The World’s Leading Lawyers for Business—Tax (Band 1)

Chambers Canada: Canada’s Leading Lawyers for Business—Tax (Band 1)

Tax Directors Handbook—TDH250

The Legal 500 Canada—Tax (Leading Lawyer)

Report on Business/Lexpert Special Edition Canada’s Leading Corporate Lawyers

The Canadian Legal Lexpert Directory—Corporate Tax; Estate and Personal Tax Planning: Estate and Tax Planning

The Best Lawyers in Canada—Tax Law (Lawyer of the Year 2020, Toronto)

Who’s Who Legal: Canada—Corporate Tax; Who’s Who Legal: Corporate Tax—Advisory

Expert Guides—Tax

Bar Admissions

Ontario, 1980

Education

Harvard Law School, LLM, 1979
Osgoode Hall Law School, LLB (Gold Medallist), 1977

Professional Affiliations

Canadian Tax Foundation
International Fiscal Association

Board Memberships

Graywood Developments Ltd., vice-chairman

Community Involvement

Jewish Foundation of Greater Toronto

“The best tax lawyer I have worked with – he gets the best results.”
Chambers Global 2016

John advises on tax aspects of domestic and international business ventures for significant public and private companies in Canada, the U.S. and Europe, with a focus on the real estate industry. He is lead adviser to a number of Canadian-based multinational groups on the tax structuring of their global investments.

Clients value John for his extensive domestic and international tax knowledge, with one client saying John’s advice is “brilliant.” They appreciate that he takes on complex tax issues but can “discuss them in an intelligent yet simple way.” (Chambers Global 2016)

Canadian public and private real estate companies, REITs, and funds and other multinationals rely on John’s judgment. Known for his creativity, he is a pioneer in the establishment of cross-border REITs. He frequently advises international funds and corporations on investing in Canada.

The Blackstone Group Inc.

Acting for real estate funds managed by The Blackstone Group Inc. and their affiliates in Blackstone's $6.2-billion all-cash acquisition of Dream Global Real Estate Investment Trust and the separation of its external asset manager, Dream Asset Management.

Graywood Group

Acting for the Graywood Group with the acquisition and development of Fish Creek Exchange in Calgary, Alberta, which is a new community consisting of mid-rise mixed-use buildings and townhomes.

Graywood Group

Acting for the Graywood Group on the formation of a 50/50 joint venture for the development of a 47-storey condominium tower to be located at the corner of Peter and Adelaide in Toronto, Ontario, which will contain 695 residences and ground level retail.

Granite REIT

Acted as tax counsel to Granite REIT in its sale of a real estate portfolio in the United States and Canada for $400 million.

RioCan Real Estate Investment Trust

Acted for RioCan Real Estate Investment Trust on Canadian and US tax matters in connection with the US$1.9-billion sale of its portfolio of 49 shopping centres, located in the Northeastern U.S. and Texas, to Blackstone Real Estate Partners.

Fortress Investment Group, LLC and Holiday Retirement

Acted for Fortress Investment Group, LLC and Holiday Retirement in connection with the sale of 29 Canadian senior living communities to Ventas, Inc.

Spear Street Capital, LLC

Acted for Spear Street Capital, LLC in connection with its $305-million purchase of the majority of BlackBerry Limited's real estate holdings in Canada, including its global headquarters in Waterloo, Ontario. BlackBerry sold more than 3 million square feet of space as well as vacant lands, and leased back a portion of the space.

IPC Jerusalem Ltd.

Acted for IPC Jerusalem Ltd. in connection with the development of The Waldorf Astoria Jerusalem Hotel, a new five-star hotel in Jerusalem.

Air Canada

Acted as Canadian tax counsel for Air Canada in structuring the first Canadian Enhanced Equipment Trust Certificate (EETC) financing, permitting Air Canada to efficiently finance the acquisition of aircraft valued at over $900 million.

CIBC World Markets and RBC Dominion Securities

Acted in Canada and the U.S. for a syndicate of underwriters led by CIBC World Markets and RBC Dominion Securities in connection with the $114 million initial public offering of WPT Industrial REIT, Canada's only REIT focused exclusively on the U.S. industrial real estate sector.

BMO Nesbitt Burns Inc. and CIBC World Markets Inc.

Acted for a syndicate of underwriters led by BMO Nesbitt Burns Inc. and CIBC World Markets Inc. in connection with the $228-million initial public offering of Milestone Apartments Real Estate Investment Trust, the first IPO in the world of a qualifying U.S. REIT by a non-U.S. entity.

Granite Real Estate Inc.

Acted as Canadian and U.S. tax counsel to Granite Real Estate Inc. in its conversion under a plan of arrangement to an international stapled-unit REIT with an initial (NYSE/TSX) market capitalization of $1.8 billion. Granite REIT was the first REIT to qualify as a REIT for Canadian income tax purposes while holding both a Canadian and international portfolio; and also the first to achieve flow-through treatment for its U.S. portfolio by electing to be a partnership for U.S. purposes and utilizing a U.S. private REIT.

Article

Update on REITs and Structuring Public Vehicles for Investment in Canadian and Foreign Real Estate

Dec. 31, 2014 - Report of Proceedings of Sixty-fifth Tax Conference, 2013 Tax Conference Report (Canadian Tax Foundation)

Speaking Engagement

Canadian Tax Foundation, 2013 annual conference, “Update on REITs and Structuring Public Vehicles for Investment in Canadian and Foreign Real Estate”

Jan. 01, 2013

Speaking Engagement

OECD and the Italian Council of Ministers, Milan seminar, “Capital Gains on Shares Under Reorganizations”

Jan. 01, 2012

Chambers Global: The World’s Leading Lawyers for Business—Tax (Band 1)

Chambers Canada: Canada’s Leading Lawyers for Business—Tax (Band 1)

Tax Directors Handbook—TDH250

The Legal 500 Canada—Tax (Leading Lawyer)

Report on Business/Lexpert Special Edition Canada’s Leading Corporate Lawyers

The Canadian Legal Lexpert Directory—Corporate Tax; Estate and Personal Tax Planning: Estate and Tax Planning

The Best Lawyers in Canada—Tax Law (Lawyer of the Year 2020, Toronto)

Who’s Who Legal: Canada—Corporate Tax; Who’s Who Legal: Corporate Tax—Advisory

Expert Guides—Tax

Bar Admissions

Ontario, 1980

Education

Harvard Law School, LLM, 1979
Osgoode Hall Law School, LLB (Gold Medallist), 1977

Professional Affiliations

Canadian Tax Foundation
International Fiscal Association

Board Memberships

Graywood Developments Ltd., vice-chairman

Community Involvement

Jewish Foundation of Greater Toronto