Michael N. Kandev

Partner

Michael N. Kandev

Michael N. Kandev

Partner

Bar Admissions
  • Québec, 2003
    Ontario, 2002

Michael’s clients turn to him for meticulous and innovative tax advice.

Michael provides advice to corporations and individuals on the tax aspects of their transactions, both in Canada and internationally. He works with major Canadian, U.S. and other publicly traded companies, private equity and hedge funds and tax-exempt institutions on investments, financings, mergers and acquisitions, reorganizations and real estate and resource projects. Clients also choose Michael to provide counsel on disputes with tax authorities. He has extensive expertise in international tax issues.

Michael is a frequent speaker at tax conferences in Canada and abroad. He is a contributing editor to the CCH International Tax Journal and is councillor and secretary of the Canadian branch of the International Fiscal Association.

Michael N. Kandev

Partner

Michael’s clients turn to him for meticulous and innovative tax advice.

Michael provides advice to corporations and individuals on the tax aspects of their transactions, both in Canada and internationally. He works with major Canadian, U.S. and other publicly traded companies, private equity and hedge funds and tax-exempt institutions on investments, financings, mergers and acquisitions, reorganizations and real estate and resource projects. Clients also choose Michael to provide counsel on disputes with tax authorities. He has extensive expertise in international tax issues.

Michael is a frequent speaker at tax conferences in Canada and abroad. He is a contributing editor to the CCH International Tax Journal and is councillor and secretary of the Canadian branch of the International Fiscal Association.

Agrium Inc.

Acted as Canadian tax counsel to Nutrien Ltd. in its acquisition, for a purchase price of over A$468 million by way of a scheme of arrangement under Australian law, of Ruralco Holdings Limited, which is listed on the Australian Securities Exchange (ASX: RHL) and is one of Australia's leading agriservice businesses.

Power Energy Corporation

Acted for Power Energy Corporation in its acquisition of Nautilus Solar Energy, LLC, a leading U.S. solar developer and asset manager, from management and Virgo Investment Group.

Valmet Technologies and Services Inc.

Acted as Canadian counsel to Valmet Technologies and Services Inc. in its acquisition of all the issued and outstanding shares of GL&V Canada Inc., a global provider of technologies and services to the pulp and paper industry.

Nutrien Ltd.

Acted as Canadian tax counsel to Nutrien Ltd. in its acquisition of Actagro, LLC, a leading developer, manufacturer and marketer of environmentally sustainable soil and plant health products and technologies.

GMP Securities L.P.

Acted for a syndicate of underwriters led by GMP Securities L.P. and comprising Desjardins Securities Inc., National Bank Financial Inc., Acumen Capital Finance Partners Limited, Scotia Capital Inc., RBC Dominion Securities Inc., Raymond James Ltd., Canaccord Genuity Corporation and PI Financial Corp. in a bought deal offering of 7,142,857 common shares of Goodfood Market Corp. for gross proceeds to the corporation of approximately $25 million.

Caisse de dépôt et placement du Québec

Acted for Caisse de dépôt et placement du Québec (Caisse) and CDP Financial Inc. in CDP Financial's establishment and launch of a US$20-billion senior notes program guaranteed by Caisse, including an initial offering by CDP Financial of US$2 billion in senior notes under the program.

GAEA Grand Holdings Limited

Acted for GAEA Grand Holdings Limited, a leading global interactive entertainment company, in its investment in Behaviour Interactive Inc.

Interactive Validated Solutions 88 Inc.

Acted for Interactive Validated Solutions 88 Inc. (Pivot 88) in connection with an equity investment by Newtimes Development Ltd.

Nutrien Ltd.

Acted as Canadian tax counsel to Nutrien Ltd. in the sale to SDIC Mining Investment Co. Ltd. of 23,294,614 common shares of Arab Potash Company for gross proceeds of $502 million.

Power Energy Eagle Creek, LLP

Acted for a joint venture of Power Energy Corporation, a subsidiary of Power Corporation of Canada, and Claridge Inc. in the sale of their majority interest in Eagle Creek Renewable Energy, LLC, an operator of 63 hydropower facilities in the United States, representing 216 MW of capacity.

A group of investors

Acted for a group of investors regarding MPX Bioceutical Corporation's issuance, through a wholly owned Luxembourg subsidiary, of US$40 million in secured convertible original issue discount notes.

Nutrien Ltd.

Acted as Canadian tax counsel to Nutrien Ltd. in respect of the sale to Tianqi Lithium Corporation of Nutrien's 62,556,568 "A shares" in the capital of Sociedad Química y Minera de Chile S.A. for consideration of $65 per share in cash, representing a total gross valuation of approximately US$4.07 billion.

Michelin Group

Acted for the Michelin Group in its acquisition of Camso Inc., one of the global leaders in the design, manufacturing and distribution of off-road tires, wheels, tracks and conveyer belts, for a purchase price of US$1.7 billion. Camso has facilities in more than 25 jurisdictions world-wide.

Confidential client

Acted for a U.S. state retirement system in its joint venture with a real estate development company for the acquisition of various industrial properties in Ontario.

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.

BNP Paribas S.A.

Acted for BNP Paribas S.A. in connection with an investment by the Caisse de dépôt et placement du Québec in Innocap Investment Management Inc.

BMO Nesbitt Burns Inc.

Acted for a syndicate of agents co-led by BMO Nesbitt Burns Inc., National Bank Financial Inc. and CIBC World Markets Inc. on the following private placement by Metro Inc. to partially finance its acquisition of The Jean-Coutu Group (PJC) Inc.: $1.2 billion aggregate principal amount of 2.68% Series F senior unsecured notes due December 5, 2022; 3.39% Series G senior unsecured notes due December 6, 2027; and 4.27% Series H senior unsecured notes due December 4, 2047.

The Sentient Group

Acted for The Sentient Group in the going-private transaction of Era Resources Inc. effected through a plan of arrangement that included the consolidation of 10,290,619 pre-consolidation common shares of Era to one post-consolidation common share.

Claridge Inc.

Acted for Claridge Inc. in connection with its sale to C.H. Guenther & Son, Inc. of Les Plats du Chef, a Canada-based frozen meal and snack business.

Kruger Inc. Master Trust

Acted for Kruger Inc. Master Trust in connection with the sale of Lidya Energy, a power plant located in Lachute, Québec, that transforms the biogas released at a landfill site into electricity, to Energy Developments (Canada) Inc., a subsidiary of Energy Developments Pty Limited, a member of Australia's DUET group.

Stingray Group Inc.

Acted for Stingray Group Inc. in connection with its acquisition of all the outstanding shares of C Music Entertainment Ltd. (also known as C Music TV).

High-Net-Worth Family

Acted for a high-net-worth family on tax matters related to a reorganization of the family's corporate holdings.

High-Net-Worth Family

Advised a high-net-worth family on tax matters related to acquisition of aircraft.

The Sentient Group

Acted for The Sentient Group in connection with its US$7-million investment in Era Resources Inc. through the purchase of a convertible unsecured note.

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.

Tippmann US Holdco, Inc. (part of the G.I. Sportz Group)

Acted for G.I. Sportz Inc. in connection with the acquisition of Kee Action Sports, a leading manufacturer and distributor of paintball sporting goods, equipment and apparel, based in New Jersey with distribution facilities located across the United States, Canada and the United Kingdom.

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.

Central National-Gottesman Inc.

Acted for Central National-Gottesman Inc., a global distributor of pulp, paper and forestry products, and its subsidiary Spicers Canada ULC in connection with the acquisition of the assets and business of Spicers Canada Limited, a distributor of fine paper, sign and display media, industrial packaging and graphic arts supplies, headquartered in Vaughan, Ontario and with locations across Canada, and the related financing with Bank of America, N.A. (Canada branch), as agent.

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.

Marlin Equity Partners

Acted as Canadian counsel to global investment firm Marlin Equity Partners in connection with its acquisition of the Arcserve division from CA Technologies. Arcserve is a leading global provider of data protection software solutions with offices in 30 countries.

Groupe Trans-Inter Inc.

Acted for the GTI Group, a Montréal-based provider of specialty transport solutions, in connection with an investment by Novacap.

The Sentient Group

Acted for The Sentient Group in connection with the acquisition of Rio Madeira Comércio Importaçao e Exportaçao de Minérios, a Brazilian company operating a manganese mine. In relation to this acquisition, Sentient executed a binding term sheet with Cancana Resources Corp. whereby and pursuant to which Sentient acquired shares, warrants and convertible debentures of Cancana and the latter will subscribe for 50% of the quotas of Rio Madeira.

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.

Yoplait France SAS

Acted for Yoplait France SAS, the second largest brand in fresh dairy products in the world, in connection with its acquisition of Québec-based Liberté Brand Products from its management and investment firms, Swander Pace Capital LLC and Roynat Capital Inc.

Honeywell International Inc.

Acted for Honeywell International Inc. in connection with the $144-million acquisition of Matrikon Inc., a company specializing in software used in manufacturing operations.

Mill Road Capital, L.P.

Acted for U.S.-based private equity firm Mill Road Capital, L.P. in its successful "white knight" bid for Cossette Inc. for approximately $134 million.

Rossy and Assaly families

Acted for the founders of Dollarama Inc. in connection with the corporation's $300 million initial public offering of common shares.

Alexis Nihon Real Estate Investment Trust

Acted for Alexis Nihon Real Estate Investment Trust in the initial public offering of $85 million of trust units.

Article

Canada Enacts Multilateral Instrument: What Happens Next?, co-author

July 22, 2019 - Tax Notes International, Vol. 95, No. 4 (Tax Analysts)
Download this article.

Bulletin

Canada Enacts the OECD-Sponsored Multilateral Instrument

June 26, 2019 - Canada has enacted into law the OECD-sponsored Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The enactment of June 21, 2019 represents the penultimate step in the domestic ratification of the MLI in Canada, which will be...

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.

Speaking Engagement

Moderator, IFA International Tax Conference 2019, “MLI Implementation and OECD Developments”; Montréal, QC

May 14, 2019

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,...

Article

Expected Adverse Effects of Proposed U.S. Anti-Hybrid Regulations on Inbound Financing By Canadian MNEx, co-author

Feb. 11, 2019 - Tax Notes International, Vol. 93, No 6 (Tax Analysts)
Download this article.

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...

Bulletin

Canadian Tax Laws: A Review of 2018 and a Look Ahead to 2019

Jan. 31, 2019 - Each year at this time we offer a look back at some of the more significant income tax developments in Canada affecting domestic and international business over the past year and a look ahead to possible Canadian tax developments in the coming year. Legislative Developments in 2018Budget 2018A. ...

Article

The Tax Court of Canada Strikes Offshore eBank in Loblaw, co-author

Oct. 29, 2018 - Tax Notes International, Vol. 92, No.5 (Tax Analysts)
Download this article.

Article

Taxpayer Wins Treaty Shopping Challenge in Alta Energy Luxembourg, co-author

Sept. 14, 2018 - Tax Management International Journal (The Bureau of National Affairs, Inc.)
Download this article.

Chambers Canada: Canada’s Leading Lawyers for Business—Tax

The Lexpert/American Lawyer Guide to the Leading 500 Lawyers in Canada—Corporate Tax

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

Lexpert Guide to US/Canada Cross-Border Lawyers in Canada—Tax

The Canadian Legal Lexpert Directory—Corporate Tax (Most Frequently Recommended); Estate and Personal Tax Planning: Estate and Tax Planning

The Best Lawyers in Canada—Tax Law

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

Bar Admissions

Québec, 2003
Ontario, 2002

Education

Canadian Institute of Chartered Accountants, In-Depth Tax Course
Universiteit Leiden, LLM (International Taxation) (Cum Laude), 2006
McGill University, BCL/LLB (with Great Distinction), 2001

Professional Affiliations

Association de planification fiscale et financière
Canadian Tax Foundation
International Fiscal Association

Community Involvement

CCH International Tax Journal, contributing editor
International Fiscal Association, Canada Council, councillor and secretary

Teaching Engagements

Michael has lectured on taxation at McGill University and Université de Montréal.

Michael’s clients turn to him for meticulous and innovative tax advice.

Michael provides advice to corporations and individuals on the tax aspects of their transactions, both in Canada and internationally. He works with major Canadian, U.S. and other publicly traded companies, private equity and hedge funds and tax-exempt institutions on investments, financings, mergers and acquisitions, reorganizations and real estate and resource projects. Clients also choose Michael to provide counsel on disputes with tax authorities. He has extensive expertise in international tax issues.

Michael is a frequent speaker at tax conferences in Canada and abroad. He is a contributing editor to the CCH International Tax Journal and is councillor and secretary of the Canadian branch of the International Fiscal Association.

Agrium Inc.

Acted as Canadian tax counsel to Nutrien Ltd. in its acquisition, for a purchase price of over A$468 million by way of a scheme of arrangement under Australian law, of Ruralco Holdings Limited, which is listed on the Australian Securities Exchange (ASX: RHL) and is one of Australia's leading agriservice businesses.

Power Energy Corporation

Acted for Power Energy Corporation in its acquisition of Nautilus Solar Energy, LLC, a leading U.S. solar developer and asset manager, from management and Virgo Investment Group.

Valmet Technologies and Services Inc.

Acted as Canadian counsel to Valmet Technologies and Services Inc. in its acquisition of all the issued and outstanding shares of GL&V Canada Inc., a global provider of technologies and services to the pulp and paper industry.

Nutrien Ltd.

Acted as Canadian tax counsel to Nutrien Ltd. in its acquisition of Actagro, LLC, a leading developer, manufacturer and marketer of environmentally sustainable soil and plant health products and technologies.

GMP Securities L.P.

Acted for a syndicate of underwriters led by GMP Securities L.P. and comprising Desjardins Securities Inc., National Bank Financial Inc., Acumen Capital Finance Partners Limited, Scotia Capital Inc., RBC Dominion Securities Inc., Raymond James Ltd., Canaccord Genuity Corporation and PI Financial Corp. in a bought deal offering of 7,142,857 common shares of Goodfood Market Corp. for gross proceeds to the corporation of approximately $25 million.

Caisse de dépôt et placement du Québec

Acted for Caisse de dépôt et placement du Québec (Caisse) and CDP Financial Inc. in CDP Financial's establishment and launch of a US$20-billion senior notes program guaranteed by Caisse, including an initial offering by CDP Financial of US$2 billion in senior notes under the program.

GAEA Grand Holdings Limited

Acted for GAEA Grand Holdings Limited, a leading global interactive entertainment company, in its investment in Behaviour Interactive Inc.

Interactive Validated Solutions 88 Inc.

Acted for Interactive Validated Solutions 88 Inc. (Pivot 88) in connection with an equity investment by Newtimes Development Ltd.

Nutrien Ltd.

Acted as Canadian tax counsel to Nutrien Ltd. in the sale to SDIC Mining Investment Co. Ltd. of 23,294,614 common shares of Arab Potash Company for gross proceeds of $502 million.

Power Energy Eagle Creek, LLP

Acted for a joint venture of Power Energy Corporation, a subsidiary of Power Corporation of Canada, and Claridge Inc. in the sale of their majority interest in Eagle Creek Renewable Energy, LLC, an operator of 63 hydropower facilities in the United States, representing 216 MW of capacity.

A group of investors

Acted for a group of investors regarding MPX Bioceutical Corporation's issuance, through a wholly owned Luxembourg subsidiary, of US$40 million in secured convertible original issue discount notes.

Nutrien Ltd.

Acted as Canadian tax counsel to Nutrien Ltd. in respect of the sale to Tianqi Lithium Corporation of Nutrien's 62,556,568 "A shares" in the capital of Sociedad Química y Minera de Chile S.A. for consideration of $65 per share in cash, representing a total gross valuation of approximately US$4.07 billion.

Michelin Group

Acted for the Michelin Group in its acquisition of Camso Inc., one of the global leaders in the design, manufacturing and distribution of off-road tires, wheels, tracks and conveyer belts, for a purchase price of US$1.7 billion. Camso has facilities in more than 25 jurisdictions world-wide.

Confidential client

Acted for a U.S. state retirement system in its joint venture with a real estate development company for the acquisition of various industrial properties in Ontario.

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.

BNP Paribas S.A.

Acted for BNP Paribas S.A. in connection with an investment by the Caisse de dépôt et placement du Québec in Innocap Investment Management Inc.

BMO Nesbitt Burns Inc.

Acted for a syndicate of agents co-led by BMO Nesbitt Burns Inc., National Bank Financial Inc. and CIBC World Markets Inc. on the following private placement by Metro Inc. to partially finance its acquisition of The Jean-Coutu Group (PJC) Inc.: $1.2 billion aggregate principal amount of 2.68% Series F senior unsecured notes due December 5, 2022; 3.39% Series G senior unsecured notes due December 6, 2027; and 4.27% Series H senior unsecured notes due December 4, 2047.

The Sentient Group

Acted for The Sentient Group in the going-private transaction of Era Resources Inc. effected through a plan of arrangement that included the consolidation of 10,290,619 pre-consolidation common shares of Era to one post-consolidation common share.

Claridge Inc.

Acted for Claridge Inc. in connection with its sale to C.H. Guenther & Son, Inc. of Les Plats du Chef, a Canada-based frozen meal and snack business.

Kruger Inc. Master Trust

Acted for Kruger Inc. Master Trust in connection with the sale of Lidya Energy, a power plant located in Lachute, Québec, that transforms the biogas released at a landfill site into electricity, to Energy Developments (Canada) Inc., a subsidiary of Energy Developments Pty Limited, a member of Australia's DUET group.

Stingray Group Inc.

Acted for Stingray Group Inc. in connection with its acquisition of all the outstanding shares of C Music Entertainment Ltd. (also known as C Music TV).

High-Net-Worth Family

Acted for a high-net-worth family on tax matters related to a reorganization of the family's corporate holdings.

High-Net-Worth Family

Advised a high-net-worth family on tax matters related to acquisition of aircraft.

The Sentient Group

Acted for The Sentient Group in connection with its US$7-million investment in Era Resources Inc. through the purchase of a convertible unsecured note.

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.

Tippmann US Holdco, Inc. (part of the G.I. Sportz Group)

Acted for G.I. Sportz Inc. in connection with the acquisition of Kee Action Sports, a leading manufacturer and distributor of paintball sporting goods, equipment and apparel, based in New Jersey with distribution facilities located across the United States, Canada and the United Kingdom.

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.

Central National-Gottesman Inc.

Acted for Central National-Gottesman Inc., a global distributor of pulp, paper and forestry products, and its subsidiary Spicers Canada ULC in connection with the acquisition of the assets and business of Spicers Canada Limited, a distributor of fine paper, sign and display media, industrial packaging and graphic arts supplies, headquartered in Vaughan, Ontario and with locations across Canada, and the related financing with Bank of America, N.A. (Canada branch), as agent.

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.

Marlin Equity Partners

Acted as Canadian counsel to global investment firm Marlin Equity Partners in connection with its acquisition of the Arcserve division from CA Technologies. Arcserve is a leading global provider of data protection software solutions with offices in 30 countries.

Groupe Trans-Inter Inc.

Acted for the GTI Group, a Montréal-based provider of specialty transport solutions, in connection with an investment by Novacap.

The Sentient Group

Acted for The Sentient Group in connection with the acquisition of Rio Madeira Comércio Importaçao e Exportaçao de Minérios, a Brazilian company operating a manganese mine. In relation to this acquisition, Sentient executed a binding term sheet with Cancana Resources Corp. whereby and pursuant to which Sentient acquired shares, warrants and convertible debentures of Cancana and the latter will subscribe for 50% of the quotas of Rio Madeira.

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.

Yoplait France SAS

Acted for Yoplait France SAS, the second largest brand in fresh dairy products in the world, in connection with its acquisition of Québec-based Liberté Brand Products from its management and investment firms, Swander Pace Capital LLC and Roynat Capital Inc.

Honeywell International Inc.

Acted for Honeywell International Inc. in connection with the $144-million acquisition of Matrikon Inc., a company specializing in software used in manufacturing operations.

Mill Road Capital, L.P.

Acted for U.S.-based private equity firm Mill Road Capital, L.P. in its successful "white knight" bid for Cossette Inc. for approximately $134 million.

Rossy and Assaly families

Acted for the founders of Dollarama Inc. in connection with the corporation's $300 million initial public offering of common shares.

Alexis Nihon Real Estate Investment Trust

Acted for Alexis Nihon Real Estate Investment Trust in the initial public offering of $85 million of trust units.

Article

Canada Enacts Multilateral Instrument: What Happens Next?, co-author

July 22, 2019 - Tax Notes International, Vol. 95, No. 4 (Tax Analysts)
Download this article.

Bulletin

Canada Enacts the OECD-Sponsored Multilateral Instrument

June 26, 2019 - Canada has enacted into law the OECD-sponsored Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The enactment of June 21, 2019 represents the penultimate step in the domestic ratification of the MLI in Canada, which will be...

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.

Speaking Engagement

Moderator, IFA International Tax Conference 2019, “MLI Implementation and OECD Developments”; Montréal, QC

May 14, 2019

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,...

Article

Expected Adverse Effects of Proposed U.S. Anti-Hybrid Regulations on Inbound Financing By Canadian MNEx, co-author

Feb. 11, 2019 - Tax Notes International, Vol. 93, No 6 (Tax Analysts)
Download this article.

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...

Bulletin

Canadian Tax Laws: A Review of 2018 and a Look Ahead to 2019

Jan. 31, 2019 - Each year at this time we offer a look back at some of the more significant income tax developments in Canada affecting domestic and international business over the past year and a look ahead to possible Canadian tax developments in the coming year. Legislative Developments in 2018Budget 2018A. ...

Article

The Tax Court of Canada Strikes Offshore eBank in Loblaw, co-author

Oct. 29, 2018 - Tax Notes International, Vol. 92, No.5 (Tax Analysts)
Download this article.

Article

Taxpayer Wins Treaty Shopping Challenge in Alta Energy Luxembourg, co-author

Sept. 14, 2018 - Tax Management International Journal (The Bureau of National Affairs, Inc.)
Download this article.

Chambers Canada: Canada’s Leading Lawyers for Business—Tax

The Lexpert/American Lawyer Guide to the Leading 500 Lawyers in Canada—Corporate Tax

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

Lexpert Guide to US/Canada Cross-Border Lawyers in Canada—Tax

The Canadian Legal Lexpert Directory—Corporate Tax (Most Frequently Recommended); Estate and Personal Tax Planning: Estate and Tax Planning

The Best Lawyers in Canada—Tax Law

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

Bar Admissions

Québec, 2003
Ontario, 2002

Education

Canadian Institute of Chartered Accountants, In-Depth Tax Course
Universiteit Leiden, LLM (International Taxation) (Cum Laude), 2006
McGill University, BCL/LLB (with Great Distinction), 2001

Professional Affiliations

Association de planification fiscale et financière
Canadian Tax Foundation
International Fiscal Association

Community Involvement

CCH International Tax Journal, contributing editor
International Fiscal Association, Canada Council, councillor and secretary

Teaching Engagements

Michael has lectured on taxation at McGill University and Université de Montréal.